# Metropolitan Transportation Planning

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/crs%3AR41068

## Record

- **Collection:** Congressional research report
- **Document type:** CRS Report
- **Published:** February 3, 2010
- **Citation:** R41068

## Text

Metropolitan Transportation Planning
/name redacted/
Specialist in Transportation Policy
February 3, 2010

Congressional Research Service
7-....
www.crs.gov
R41068

CRS Report for Congress
Prepared for Members and Committees of Congress

Metropolitan Transportation Planning

Summary
Federal law requires state and local governments to designate a metropolitan planning
organization (MPO) in each urbanized area with a population of 50,000 or more to help plan
surface transportation infrastructure and services. There are currently 381 MPOs nationwide.
Despite some strengthening of their authority over the years, MPOs have generally remained
subordinate to state departments of transportation (DOTs) in the planning and selecting
(“programming”) of projects using federal surface transportation funds. Moreover, it can be
argued that at the metropolitan level MPOs are subordinate to local governments that own and
operate many elements of the transportation system, and also control land use planning and
zoning.
Because of the perceived weakness of MPOs, some in the transportation community have argued
that they ought to be given much more power over the planning and programming of projects
using federal surface transportation funds. Some of these observers go so far as to suggest that
federal policies and programs in a number of areas, including transportation, housing, and the
environment, need to be coordinated on a metropolitan scale, and that MPOs are the
organizational venue where this should occur. Others argue that the relationship between state
government, local government, and MPOs is well-balanced and should not be changed. A third
view is that metropolitan transportation planning is controlled by planners who often harbor anticar views, and consequently, MPOs can be actually detrimental to well-functioning metropolitan
transportation systems. In this view, MPOs should be abolished or, at the very least, have their
functions significantly curtailed.
Surface transportation programs were authorized under the Safe, Accountable, Flexible, Efficient
Transportation Equity Act: A Legacy for Users (SAFETEA-LU or SAFETEA; P.L. 109-59)
covering the period FY2005 through FY2009. In lieu of a new multi-year reauthorization that is
still being considered, Congress has extended these programs and their funding several times.
Reauthorization of the surface transportation programs provides an opportunity for Congress to
reexamine policies related to MPOs and the metropolitan planning process. This report discusses
several issues that Congress may want to consider: the authority of MPOs to plan and program
funds; representation and participation in MPOs; MPO funding and technical capacity; and
implementation of livability initiatives. It may also want to consider a number of issues having to
do with planning requirements such as the need for a long-range plan, the proper scale of
planning, and the incorporation of freight transportation interests. The report begins with a brief
description of the metropolitan transportation planning process.

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Contents
Introduction ................................................................................................................................1
The Metropolitan Transportation Planning Process ......................................................................2
Issues for Congress .....................................................................................................................5
Decision-Making Authority of MPOs Relative to State DOTs................................................6
Surface Transportation Assistance Act of 2009 ................................................................7
Other Perspectives on MPO Authority.............................................................................8
Representation and Participation in MPOs........................................................................... 10
MPO Funding and Technical Capacity ................................................................................ 12
MPOs and “Livability/Sustainability” Initiatives ................................................................. 13
Legislative Proposals .................................................................................................... 14
Climate Change Mitigation, Compact Cities, and Transportation ................................... 16
Other Issues with Transportation Planning Requirements .................................................... 16
Long-Range Planning.................................................................................................... 16
Freight Transportation................................................................................................... 17
Geographic Scale .......................................................................................................... 17
Conclusion................................................................................................................................ 18

Figures
Figure 1. Federal Funds Apportioned for Metropolitan Transportation Planning,
FY2000-FY2009......................................................................................................................6

Contacts
Author Contact Information ...................................................................................................... 19

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Introduction
Since the early 1970s, federal law has required state and local governments to designate
metropolitan planning organizations (MPOs) in urbanized areas with a population of 50,000 or
more to help plan surface transportation infrastructure and services.1 There are currently 381
MPOs nationwide, of which 43 represent areas of 1 million residents or more (large MPOs), 139
represent areas of between 200,000 and 1 million (medium MPOs), and 199 represent areas of
between 50,000 and 200,000 (small MPOs).2 The foremost rationale for MPOs and metropolitan
transportation planning is that the metropolitan scale is the level at which most economic
activities, including commuting and, therefore, local highway and transit systems, are organized. 3
These “metropolitan economies” transcend local government and sometimes state boundaries,
and, as some observers have argued, are often too far removed from state capitals for state
governments to successfully oversee them. This is particularly an issue in places where a
metropolitan area is spread over more than one state.
Despite some strengthening of their authority over the years, MPOs have generally remained
subordinate to state departments of transportation (DOTs) in the planning and selecting
(“programming”) of projects using federal surface transportation funds. Moreover, it can be
argued that at the metropolitan level MPOs are subordinate to local governments that own and
operate many elements of the transportation system, and also control land use planning and
zoning.4 Because of this perceived weakness, some in the transportation community have argued
that MPOs ought to be given much more power over the planning and programming of projects
using federal surface transportation funds. Some even go so far as to suggest that federal policies
and programs in a number of areas, including transportation, housing, and the environment, need
to be coordinated at the metropolitan scale, and that MPOs are the organizational venue where
this should occur. Others argue that the relationship between state government, local government,
and MPOs is well-balanced and should not be changed. A third view is that metropolitan
transportation planning is controlled by planners who often harbor anti-car views, and,
consequently, MPOs can be actually detrimental to well-functioning metropolitan transportation
systems. In this view, MPOs should be abolished or, at the very least, have their functions
significantly curtailed.5
1
An urbanized area is defined as consisting of “contiguous, densely settled census block groups and census blocks that
meet minimum population density requirements, along with adjacent densely settled census blocks that together
encompass a population of at least 50,000 people.” U.S. Department of Commerce, Bureau of the Census, “Urban Area
Criteria for Census 2000,” 69 Federal Register 51, pp. 11663-11670. Metropolitan (statistical) areas are county-based
geographical units that typically include a large, densely settled central county together with surrounding counties that
are functionally linked with the core county as defined by commuting patterns. Consequently, unlike an urbanized area,
a metropolitan statistical area will typically encompass both urban and rural land within its borders. See Office of
Management and Budget, “Standards for Defining Metropolitan and Micropolitan Statistical Areas,” 65 Federal
Register 249, pp. 82228-82238.
2
U.S. Government Accountability Office, Metropolitan Planning Organizations: Options Exist to Enhance
Transportation Planning Capacity and Federal Oversight, GAO-09-868, September 2009, http://www.gao.gov/
new.items/d09868.pdf.
3
Peter Calthorpe and William Fulton, The Regional City: Planning for the End of Sprawl (Washington, DC: Island
Press, 2001).
4
Genevieve Giuliano, “Where Is the ‘Region’ In Regional Transportation Planning?,” in Up Against the Sprawl, ed.
Jennifer Wolch, Manuel Pastor, Jr., Peter Dreier (Minneapolis: University of Minnesota Press, 2004).
5
See, for example, Randal O’Toole, “Roadmap to Gridlock: The Failure of Long-Range Metropolitan Transportation
Planning,” Cato Institute, Policy Analysis, no. 617 (May 27, 2008), http://www.cato.org/pubs/pas/pa-617.pdf.

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For the period FY2005 though FY2009, surface transportation programs were authorized by the
Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEALU or SAFETEA; P.L. 109-59). In lieu of a new multi-year reauthorization that is still being
considered, Congress has extended these programs and their funding several times.
Reauthorization of the surface transportation programs provides an opportunity for Congress to
reexamine policies related to MPOs and the metropolitan planning process.6 Changes are also
being considered as part of climate change legislation. This report discusses several issues that
Congress may want to consider: the authority of MPOs to plan and program funds; representation
and participation in MPOs; MPO technical capacity; and implementation of
livability/sustainability initiatives. It also considers a number of other planning issues including
the requirements for a long-range plan, the proper scale of planning, and the incorporation of
freight transportation needs. These issues are discussed in detail below after a brief description of
the metropolitan transportation planning process.

The Metropolitan Transportation Planning Process
The federal requirement for transportation planning in urban areas, although not MPOs, dates to
the Federal-Aid Highway Act of 1962 (P.L. 87-866), which called for “a continuing
comprehensive transportation planning process carried on cooperatively by states and local
communities.”7 MPOs themselves have been required as part of the transportation planning
process in urbanized areas since the enactment of the Federal-Aid Highway Act of 1973 (P.L. 9387) (23 U.S.C. §134; 49 U.S.C. §5303). In general, the designation of the MPO, the design of its
organizational structure, and voting representation within the MPO are to be agreed upon by the
governor of the state and the general-purpose local governments of the area. In urbanized areas of
200,000 residents or more, designated as transportation management areas (TMAs), federal law
requires that the MPO must consist of local elected officials, officials from public agencies that
operate major modes of transportation (transit agencies, port authorities, etc.), and appropriate
state officials (23 U.S.C. §134(d)(2); 49 U.S.C. §5303(d)(2)). Typically, these officials form a
policy board in which some members have voting rights and others do not. Day-to-day operations
of an MPO are usually managed by an executive director appointed by the board, and a staff
composed largely of professional planners. The number of staff supporting the work of the MPO
is typically very small. The Government Accountability Office (GAO) recently found the average
(mean) number of full-time and part-time staff working for small MPOs was 3.2 and 1.4,
respectively. For medium MPOs the averages were 8.2 full time and 1.5 part time staff, and for
large MPOs the averages were 49.3 full time and 3.9 part time.8 With few permanent staff,
smaller MPOs often hire consultants to do technical work, rely on help from the state DOT, or
both.
The two major requirements of every MPO are the preparation of a long-range, multi-modal
Metropolitan Transportation Plan (MTP) covering a minimum period of 20 years, and a
Transportation Improvement Program (TIP) covering four years. The MTP must be updated at
least every five years, or four years in areas with air quality problems, and the TIP must be
updated at least every four years. The MTP is required to include an assessment of transportation
6
CRS Report R40780, Surface Transportation Reauthorization Legislation in the 111th Congress: Summary of Selected
Major Provisions, coordinated by (name redacted).
7
P.L. 87-866, Section 134.
8
GAO, 2009, p. 12.

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supply and demand in the metropolitan area; operational and infrastructure investment strategies
to improve the condition and performance of the system; estimates of transportation’s effects on
environmental quality and how these effects can be mitigated; and a financial plan that shows
how the MTP can be implemented. Two important components of developing the long-range plan
are preparation of travel demand forecasts and estimates of other inputs and outputs such as
future land use patterns and pollutant emissions. 9
The four-year TIP is a priority list of proposed federally supported highway and transit projects
and strategies. Federal law requires that the list of projects and strategies must be “fiscally
constrained” in that the program must be supported by reasonable estimates of available funding.
To put it another way, the TIP must include a priority list of projects and strategies over the
coming four years that have a reasonable chance of being accomplished with available funding.
The TIP must be approved by both the MPO and the governor (although the actual approval is
often delegated to the state DOT), and be consistent with the MTP. Federally supported projects
must be selected from the approved TIP. Large and medium MPOs, those in urbanized areas of
200,000 residents or more, have the authority to select projects from the TIP in consultation with
the state and public transit operators, except projects carried out on the National Highway System
(NHS), or under the Bridge Program and Interstate Maintenance (IM) Program. In those cases,
the state DOT has the authority to select projects from the TIP in cooperation with the MPO.
MPOs in small urban areas, however, have less authority than those in larger areas. This is
because power to select highway projects from the TIP is given to the state and power to select
transit projects is given to the designated recipients of public transit funding. Project selection by
the state or transit system, however, must be done in cooperation with the MPO, a stronger
requirement than consultation.
The transportation plans of a metropolitan area must be consistent with transportation plans that
are required at the state level. Moreover, in metropolitan areas that are in nonattainment or
maintenance status for air quality,10 transportation plans must be in conformity with the state
implementation plan (SIP) required to bring the area into compliance with air pollution
standards.11 The local MPO policy board is responsible for making a conformity determination
between the regional transportation plan and regional air quality plan. This determination must be
made at least every four years, when a MTP or TIP is updated or amended, or within 24 months
after a SIP or SIP revision is approved by the Environmental Protection Agency. 12
Some argue that development of the TIP, also known as project “programming,” is the most
important activity of an MPO because it provides the potential for setting budgetary priorities.13
9
U.S. Department of Transportation, Federal Highway Administration, Federal Transit Administration, The
Transportation Planning Process: Key Issues, FHWA-HEP-07-039, Washington, DC, 2007,
http://www.planning.dot.gov/documents/briefingbook/bbook_07.pdf.
10
A nonattainment area is an area designated by the Environmental Protection Agency under the Clean Air Act (CAA)
as not meeting the national primary or secondary ambient air quality standards for one or more designated pollutants. A
maintenance area is an area that was previously designated nonattainment and subsequently redesignated to attainment
subject to the development of a maintenance plan required under the CAA.
11
For more information, see CRS Report RL32106, Transportation Conformity Under the Clean Air Act: In Need of
Reform?, by (name redacted).
12
U.S. Department of Transportation, The Transportation Planning Process: Key Issues, 2007.
13

Paul G. Lewis and Mary Sprague, Federal Transportation Policy and the Role of Metropolitan Planning
Organizations in California, Public Policy Institute of California, San Francisco, CA, April 1997, p. 8,
http://www.ppic.org/content/pubs/report/R_497PLR.pdf.

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Prior to enactment of the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA; P.L.
102-240), a TIP did not need to be fiscally constrained, thus, a common complaint was that such
documents were long “wish lists” from which the state could choose the projects to fund. By
contrast, since ISTEA, MPOs, particularly those in areas designated as TMAs, have had a say in
developing the TIP and in selecting projects from the TIP to be implemented. Moreover, ISTEA is
also said to have empowered MPOs by giving them primary authority over Surface
Transportation Program (STP) funds designated for projects in specific urban areas, so-called
“suballocated” funds, and, to a lesser extent, authority over Congestion Mitigation and Air
Quality Improvement Program (CMAQ) funds.
The planning area for which the MPO is generally responsible is the urbanized area and the area
likely to become urbanized over the next 20 years, and may, therefore, encompass the entire
metropolitan statistical area.14 The planning process is required to be multi-modal, and is to
include consideration of a range of factors: economic competitiveness; safety; security;
accessibility and mobility of people and freight; environmental quality, energy conservation,
quality of life, and consistency with growth and economic development patterns; intermodal
connectivity; efficient management and operation of the system; and preservation of the existing
system (23 U.S.C. §134(h)(1); 49 U.S.C. §5303(h)(1)). In areas designated as TMAs, planning
must include a congestion management process that encompasses travel demand reduction and
operational management strategies (23 U.S.C. §134(k)(3); 49 U.S.C. §5303(k)(3)). 15 In
nonattainment areas “federal funds may not be advanced ... for any highway project that will
result in a significant increase in the carrying capacity for single-occupant vehicles unless the
project is addressed through a congestion management process” (23 U.S.C. §134(m)(1); 49
U.S.C. §5303(m)(1)).
The metropolitan planning process, in areas designated as TMAs, must be certified by the
Secretary of Transportation as being carried out according to federal law. Working together,
FHWA and FTA perform certification reviews. Certification is required not less often than once
every four years. Certification is based on the way in which the planning is carried out, not the
success or failure of the projects and strategies ultimately employed. Among other things, a
certification review will examine the participation of interested parties in the planning process.
Federal law requires that at a minimum, stakeholders, including freight shippers, public transit
operators, and the general public, be given reasonable opportunity to comment on the
transportation plan. To that end, MPOs are required to develop a public participation plan. If
federal certification is not granted, the Secretary may withhold 20% of highway and transit
project funds attributable to the area.
In addition to the activities prescribed by federal law, some MPOs carry out other activities that
may be given to them by state or local government. These include land-use planning, project
implementation, transit operations, and environmental planning in addition to air quality
14

As noted earlier, metropolitan statistical areas are county-based geographical units that typically comprise a large,
densely settled central county and the surrounding counties that are functionally linked with the core county as defined
by commuting patterns. Consequently, unlike an urbanized area, a metropolitan statistical area will typically encompass
both urban and rural land within its borders.
15
Travel demand reduction strategies include incentives to ride public transit, carpool, and work at home. Operational
management strategies can include incident management, transit priority, and traveler information, among others. For
more information, see U.S. Department of Transportation, Federal Highway Administration, An Interim Guidebook on
the Congestion Management Process in Metropolitan Transportation Planning, FHWA-HOP-08-008, Washington,
DC, February 2008, http://www.ops.fhwa.dot.gov/publications/cmpguidebook/cmpguidebook.pdf.

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emissions analysis. According to GAO, 70% of MPOs have some land use planning
responsibilities, 37% implement projects, 21% do additional environmental planning such as
water quality planning, and 16% operate transit service. 16
Although metropolitan transportation planning and MPOs are supported with resources from
federal, state, and local government, federal funding typically provides a majority of that support.
About 80% of MPOs get a majority of planning funds from the federal government.17 Federal
funding for metropolitan transportation planning is predominantly provided through a 1.25%
deduction of federal highway funding authorized for five highway programs: IM, NHS, Bridge,
STP, and CMAQ. These deducted funds are apportioned to each state as metropolitan planning
funds based primarily on the ratio of urbanized population in a state to the total urbanized
population, although every state receives at least 0.5% of the total nationwide apportionment.
Federal metropolitan planning funds apportioned to a state are distributed to individual MPOs
based on a formula developed by the state in consultation with the MPOs and approved by
FHWA. In addition to planning funds apportioned in this way, NHS, STP, and Equity Bonus (EB)
funds may be used for planning activities. Federal transit funds are also available for metropolitan
planning (Section 5303 funds). MPOs are required to match federal funds with 20% of funds
from state and local sources. For FY2009, nearly $400 million in federal funds were apportioned
for metropolitan planning, with about $304 million from federal highway funds and $94 million
from federal transit funds. Federal funds apportioned for metropolitan transportation planning
since 2000 can be seen in Figure 1.

Issues for Congress
Since the first federal requirements for urban transportation planning in the early 1960s and for
MPOs in the early 1970s, Congress has modified and generally strengthened the metropolitan
transportation planning process and the role of MPOs. Arguably, the biggest changes date to the
enactment of the ISTEA and the requirements of the Clean Air Act Amendments of 1990 (CAAA;
P.L. 101-549). Among other changes, ISTEA brought in the requirements for a fiscally
constrained TIP, suballocated funds to urbanized areas, funding to air quality non-attainment and
maintenance areas through CMAQ, and, in concert with the CAAA, made air quality an
important goal of metropolitan planning. ISTEA also increased the amount of federal planning
funds provided to MPOs. Subsequent surface transportation reauthorization legislation, the
Transportation Equity Act for the 21st Century, as amended, enacted in 1998 (TEA-21; P.L. 105178; P.L. 105-206) and SAFETEA, enacted in 2005, reaffirmed these changes with some
modifications.
With the initial expiration of SAFETEA at the end of FY2009, the role of MPOs is once again
being debated in Congress in the context of reauthorizing the federal surface transportation
programs. There appear to be five major issues that Congress may consider in this debate: (1) the
authority of MPOs relative to state DOTs to plan and program funds; (2) representation and
participation in MPOs; (3) MPO funding and technical capacity; (4) MPOs and the
implementation of livability/sustainability initiatives; and (5) other issues with transportation
planning requirements.
16
17

GAO, 2009, pp. 13-15.
Ibid., p. 12.

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Figure 1. Federal Funds Apportioned for Metropolitan Transportation Planning,
FY2000-FY2009
($ Millions)
450

400

350
Transit Funds
Highway Funds

$ Millions

300

250

200

150

100

50

FY2000

FY2001

FY2002

FY2003

FY2004

FY2005

FY2006

FY2007

FY2008

FY2009

Source: U.S. Department of Transportation, Federal Highway Administration and Federal Transit
Administration.

Decision-Making Authority of MPOs Relative to State DOTs
Possibly the most important issue for Congress with respect to metropolitan transportation
planning is the decision-making authority of MPOs, particularly with respect to the authority of
state DOTs, and the effect this has on the geography of infrastructure funding. One prominent
view on this issue is that under current law MPOs are relatively powerless because most federal
highway funding is controlled by the states. Because many state legislatures and state DOTs have
historically been dominated by rural areas, it has been argued that, consequently, urban regions
have generally fared relatively poorly in highway funding.18 As one transportation coalition has
asserted, a “reason to increase the decisionmaking authority and ability of MPOs is that many
states continue to penalize metropolitan areas in the distribution of transportation funds.”19
Moreover, adherents to this view suggest that even with money that is directed to urban areas, the
authority of MPOs is weak because project selection by MPOs must be done in cooperation or
18

Robert Puentes and Linda Bailey, “Increasing Funding and Accountability for Metropolitan Transportation
Decisions,” and Edward Hill et al., “Slanted Pavement: How Ohio’s Highway Spending Shortchanges Cities and
Suburbs,” in Bruce Katz and Robert Puentes, eds., Taking the High Road: A Metropolitan Agenda for Transportation
Reform, Washington, DC, Brookings Institution Press, 2005.
19
Transportation for America, The Route to Reform: Blueprint For a 21st Century Federal Transportation Program,
Washington, DC, 2009, p.153 (emphasis in original), http://t4america.org/docs/blueprint_full.pdf.

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consultation with the state DOT and local governments. Indeed, when local control exists it still
tends to rest with local jurisdictions that are often more interested in receiving their “fair share” of
project money than on solving regional transportation problems.20
Another effect of state DOTs being largely in control of highway funding, these observers argue,
is a bias towards highway construction projects of a type that is more suited to rural
environments. Adherents to this view contend that highway improvements tend to be of the larger
kind that accommodate faster speeds, and, thus, are not built with non-vehicular traffic in mind.
Consequently, it is said, there has been much less emphasis on transportation improvements that
might be better suited to urban environments, including roads with slower design speeds that
accommodate bicyclists and pedestrians, operations and management improvements such as
signal timing, and the use of “highway” funds on other modes such as transit. This alleged
spending bias has implications for urban development because, as one think tank put it, “state
DOTs’ traditional focus on highway maintenance and construction fosters metropolitan
decentralization that negatively impacts cities and older suburbs.”21
According to this view, more federal funding needs to be directed to urbanized areas, and greater
power to make infrastructure funding decisions needs to be placed in the hands of MPOs.
Providing this greater authority is often linked to requiring greater accountability for
transportation outcomes. One coalition of transportation groups argues for “empowering regions
to shape their future by giving them more direct funding and decision-making authority, while
holding them accountable for results.”22

Surface Transportation Assistance Act of 2009
Some of these ideas are contained in the proposed Surface Transportation Assistance Act of 2009
(STAA), a bill that has not been formally introduced and, hence, is unnumbered, but nonetheless
has been subject to markup by the House Committee on Transportation and Infrastructure,
Subcommittee on Highways and Transit.23 Although the bill is incomplete, lacking funding data
and other details on several of what might be the most significant features in the bill, there are a
number of legislative proposals pertaining to MPOs. STAA creates the Metropolitan Mobility and
Access (MMA) Program which would provide funding and financing authority directly to MPOs
in areas of 500,000 or more. 24 According to the draft bill,
[t]he purpose of the metropolitan mobility and access program shall be to provide multimodal transportation funding and financing authority directly to metropolitan planning
organizations, thereby allowing MPOs broad multi-modal flexibility in planning and
implementing programs of surface transportation projects to reduce vehicular congestion, to
maximize mobility and access of people and goods, and to improve safety, environmental
sustainability, and livability in large urbanized areas.25

20

Downs, Anthony and Robert Puentes, “The Need for Regional Anticongestion Policies,” in Katz and Puentes, 2005.
Robert Puentes and Linda Bailey, 2005, p. 153.
22
Transportation for America, 2009, p.11.
23
CRS Report R40780, Surface Transportation Reauthorization Legislation in the 111th Congress:
Summary of Selected Major Provisions, coordinated by (name redacted).
24
Whether all MPOs are authorized under state and local laws to receive funds directly from the federal government is
uncertain (See 23 U.S.C. Section 134).
25
Surface Transportation Authorization Act of 2009, Section 1205, http://transportation.house.gov/Media/file/
(continued...)
21

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To be eligible to receive funding, an MPO will have to develop a metropolitan mobility plan that
is approved by DOT. The MMA requires an MPO to have an approved metropolitan mobility
plan, supported by performance-based goals and metrics, to receive funds. Beginning in FY2012,
continued funding is contingent on providing an annual report which documents progress toward
the goals, reasons for failing to meet any of the goals, and a new plan by which the goals will be
met going forward.
Providing federal highway funding directly to MPOs would be a major change in the way the
Federal-Aid Highway Program operates, and could be a major shift in authority from the states to
the MPOs. Apart from the question of the relative power of MPOs and state DOTs, there are some
in the transportation community who worry about the ability of some MPOs, particularly those in
small and medium size urbanized areas, to administer federal funds efficiently. Another concern,
at least in some states, is that MPOs may not have the legal authority to receive federal funds
directly. Although most MPOs are not officially units of government, but instead cooperative,
intergovernmental organizations, the creation and organization of MPOs is, by and large, dictated
by state law. Consequently, changes to funding mechanisms and the authority of MPOs at the
federal level may require states and local governments to reevaluate MPO governance structures.

Other Perspectives on MPO Authority
Putting the intergovernmental question aside, the case can be made that unless federal funding is
very substantial and comes with much stronger authority over project implementation and other
matters, such as land use, MPOs are likely to remain relatively weak. This is because real power
will still be centered within state/local government, including single-mode entities such as transit
agencies, and local officials that typically make up the governing board of an MPO will find it
hard to make decisions that while good for the region may be detrimental to the interests of their
home jurisdiction. For example, a commission established by the State of Washington to examine
transportation issues in the Puget Sound region found that there were 128 agencies managing
some aspect of transportation in the four-county area. The commission noted that
formal and informal discussions with over 100 individuals and more than 50 agencies reveal
the difficulties that these individuals and agencies face when attempting to prioritize regional
interests in transportation infrastructure. These officials bring hard work, intelligence and
insight to their roles. However, they are charged with advancing the interests of an individual
agency, district, city, county or the state as a whole, or with protecting the interests of a
particular mode of transportation, such as roads or transit.26

It recommended, therefore, that
the [Washington State] Legislature create a new 15-member Puget Sound Regional
Transportation Commission (PSRTC) that has authority and responsibility for planning,
prioritizing and funding all modes of regional transportation for the four-county area.... Our
recommendations suggest that the agency should have responsibility for land use, roads and

(...continued)
Highways/HPP/OBERST_044_xml.pdf.
26
Regional Transportation Commission, Final Report, December 31, 2006, pp. 5-1.

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transit, including the three current regional entities. We believe the agency should have
taxing, tolling and borrowing authority. 27

Although this recommendation, at least in terms of transportation planning, was repeated by the
Washington State Auditor in a study of highway traffic congestion in the Puget Sound region—
with the additional thought that this single control could be given to either the Washington State
DOT or a new regional entity—it is perhaps not surprising that such a powerful regional entity
has not been established to date.28
An opposing view is that Congress should abolish federal involvement in metropolitan planning
which deals with mostly local or regional concerns.29 In this view, metropolitan transportation
planning and MPOs have largely failed, not because they are too weak, but because they are
beholden to a special-interest coalition of government planners, private consultants, and others
who favor behavioral “smart growth” strategies to deal with regional transportation problems
such as highway congestion, air pollution, and greenhouse gas (GHG) emissions. Smart growth
strategies, it is argued, rely on making urban areas more dense through land use regulation, and
by placing greater funding emphasis on alternatives to cars and trucks such as transit, bicycling,
and walking. According to this view, these behavioral tools failed in dealing with urban air
quality problems, and they will fail to reduce GHG emissions, particularly if cost effectiveness is
used as a criterion.
As a corollary to this view, the case can be made that while urban regions do relatively poorly in
terms of highway funding, they more than make up for it in terms of transit funding that is
typically provided directly to transit operators and is supported by highway user fees.
Additionally, it might be argued that highway funding tends to be directed to more rural parts of
the state because there are great needs for intercity connectivity, even for urban residents, and it is
at the rural fringes of urban regions where population growth tends to be fastest, and, hence,
where infrastructure needs are greatest.
A third view is that Congress should make little or no change to the current authority of MPOs
nor to the relationship between MPOs and state DOTs. This is the view of the American
Association of State Highway and Transportation Officials (AASHTO), the association of state
DOTs. In its view, the current process properly assigns authority to the owner of each element in
the hierarchy of the highway system and requires a proper level of cooperation between different
levels of government through the MPO. It argues that
changes to this relationship risk a loss of state control over state-owned roads, including
Interstate highways and National Highway System facilities, potentially allowing local
concerns to dominate broader state and national transportation and economic needs such as
freight movement through and around these urban areas.30

27

Ibid., introductory letter to the governor, State Senate, and State House of Representatives.

28

Washington State Auditor, Washington State Department of Transportation, Managing and Reducing Congestion in
the Puget Sound, Performance Audit, Report No. 1000006, Olympia, WA, October 2007, http://www.sao.wa.gov/
auditreports/auditreportfiles/ar1000006.pdf.
29
Randal O’Toole, 2008.
30
American Association of State Highway and Transportation Officials (AASHTO), “AASHTO Authorization Policy,
Topic IV: Project and Program Development and Delivery,” p. 35, http://www.transportation.org/sites/policy_docs/
docs/iv.pdf.

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Representation and Participation in MPOs
As noted earlier, the organizational structure of an MPO, including the make-up of the governing
board and voting rights, and its decision-making processes (e.g., majority vote or consensus) are
largely at the discretion of state and local lawmakers. Despite variation in the way MPOs are
organized around the country, MPOs are typically governed by a board of voting members made
up of local elected representatives selected from member jurisdictions. Other voting and nonvoting members may be appointed ex officio, such as the head of the local transit agency, or by
gubernatorial appointment, such as a representative from the state DOT. Many MPOs have
advisory committees that support the policy board, such as those dedicated to technical, freight,
air quality, and bicycle/pedestrian issues, and many have a citizens advisory committee. 31
Voting representation on MPO policy boards varies widely, but voting weighted by the population
of member jurisdictions is relatively uncommon. 32 Because the resident population of member
jurisdictions is often vastly different, a common criticism is that this creates a serious problem of
unequal representation, or malapportionment, on the MPO policy board. A number of studies
have found that this malapportionment tends to over-represent suburban residents at the expense
of central city residents, and that this geographical disparity also tends to result in an underrepresentation of racial and ethnic minorities in the decision-making of MPOs.33
One study of MPOs in the 50 largest urbanized areas found that only 16 provided for voting
weighted by population.34 In five of the 16, the weighting is proportional to population, but in the
remaining 11 the weighting provides additional votes to the more populous jurisdictions, but not
in proportion to population size. The study found that, on average, while central city populations
make up 59% of residents overseen by MPOs, they only receive 29% of votes on MPOs’ boards.
In contrast, suburban residents make-up 26% of the population, but receive 55% of the votes. The
remaining 15% of votes go to non-local entities such as transit agencies and state DOTs. The
study also showed that racial and ethnic minorities also tended to be underrepresented among
MPO voting board members in part because of the geographical bias. While non-Hispanic white
residents of the 50 urbanized areas studied were 61% of the population, 88% of the voting
members on MPO boards were non-Hispanic white. Correspondingly, other groups were
underrepresented: black 15% population, 7% voting board members; Hispanic 17% population,
3% voting board members; Asian 6% population, 1% voting board members.
The effects of underrepresentation of central cities and racial and ethnic minorities in the
composition of MPO voting boards are still not fully clear, but one research study has found a
link between representation and the share of funding directed to transit. This study of 20 large

31
Alexander Bond and Jeff Kramer, “Governance of Metropolitan Planning Organizations: Board Size, Composition,
and Voting Rights,” Paper presented at the Transportation Research Board annual meeting, Washington, DC, January
11, 2010.
32
Ibid.
33
Paul G. Lewis, “Regionalism and Representation: Measuring and Assessing Representation in Metropolitan Planning
Organization,” Urban Affairs Review, vol. 33, no. 6 (July 1998), pp. 839-853; Association of Metropolitan Planning
Organizations, “AMPO Survey Results: Policy Board Structure,” at http://www.ampo.org/assets/
62_policyboardstructure.doc; Thomas W. Sanchez, An Inherent Bias? Geographic and Racial-Ethnic Patterns of
Metropolitan Planning Organization Boards, Brookings Institution, Washington, DC, January 2006,
http://www.brookings.edu/~/media/Files/rc/reports/2006/01transportation_sanchez/20060124_mpos.pdf.
34
Sanchez, 2006.

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MPOs found that for every extra vote suburban areas receive on an MPO board between 1% and
7% less funds were directed to transit in the MPO budget. 35
Although malapportionment exists in many MPOs, an alternative view is that it does not have as
much of an effect on decision-making as the research would seem to suggest. This is because a
large number of MPOs work on a consensus basis, and, in MPOs where voting in proportion to
population size is provided for, in practice it is rarely used. 36 The case can be made that less than
proportional representation prevents the most populous jurisdiction(s) in a metropolitan area from
dominating the MPO. Less populous jurisdictions also can be geographically large or rapidly
growing and, thus, it might also be argued, deserve more say than population alone would
indicate.
Furthermore, it might be argued that MPO decisions with respect to minority and low-income
populations are constrained by other federal laws and regulations including Title VI of the Civil
Rights Act and Executive Order 12898 (Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations). Based on Title VI requirements, an MPO
must develop a public participation plan for “seeking out and considering the needs of those
traditionally underserved by existing transportation systems, such as low-income and minority
households, who face challenges accessing employment and other services” (23 CFR 450.318). As
noted earlier, the metropolitan planning process, in areas designated as TMAs, must be certified
by the Secretary of Transportation as being carried out according to federal law, and, thus, an
MPO certification review is when compliance with these requirements can be enforced. But critics
contend that withholding or providing conditional certification is a relatively weak way of
enforcing participation requirements, and one rarely used. 37 Also, these public participation
requirements do not directly address the question of representation on the local MPO policy
board. On the other hand it might be argued that many MPOs have made a legitimate attempt
with limited resources to involve traditionally underserved communities, and that often it is
difficult to generate involvement with seemingly arcane deliberations, far removed from the usual
topics of interest to such communities.
If Congress believes it is desirable to alter local representation and participation in MPOs, there
are a number of possible avenues that it might take. Congress could require that voting on MPO
boards be in proportion to the population of the member jurisdictions. This approach is taken in
the STAA. Another possibility is to strengthen the federal certification requirements for MPOs,
especially those in TMAs, to take greater account of public participation, and to more formally
consider voting and non-voting board membership, advisory committee membership, and voting
mechanisms as possible sources of bias.38 A third suggestion is for MPOs to place greater
emphasis on public participation, recruitment of minorities to serve on advisory committees, and
the diversity of policy boards, including non-voting members.39 Congress might support this
essentially state and local initiative by providing DOT with more funding to develop and share
techniques, including leadership training, for achieving such ends.
35

Arthur C. Nelson, Thomas W. Sanchez, and James F. Wolf, et al., “Metropolitan Planning Organization Voting
Structure and Transit Investment Bias: Preliminary Analysis with Social Equity Implications,” Transportation
Research Record, vol. 1895 (2004), pp. 1-7.
36
Association of Metropolitan Planning Organizations.
37
Sanchez, 2006.
38
Ibid.
39
Ibid.

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MPO Funding and Technical Capacity
Another concern with MPOs is that most do not have the technical capacity, or the funding, to
successfully fulfill federal planning requirements, including developing the long-range plan, the
TIP, and conducting public meetings. As noted earlier, apart from a handful of MPOs in the
largest areas, MPOs tend to have small executive and technical staffs, and many rely on staff time
and expertise from other agencies, typically state DOTs. One specific problem is conducting the
modeling that is required as the basis of forecasting future travel growth, capacity needs, and, in
air quality non-attainment and maintenance areas, conformity with air quality plans. As the
modeling requirements have become increasingly complex over time, many MPOs have had
trouble keeping up. Additionally, many MPOs have difficulties acquiring the data they need
support their modeling efforts. According to a report of the Transportation Research Board
(TRB), a part of the National Academies, while federal requirements for modeling have
increased, federal funding for model development has been “greatly reduced.”40
One possible option for congressional action would be to provide more federal funding for
planning activities, including more funding for model development and data collection. This
might be done by increasing the overall funding for transportation programs, or by taking funds
from other transportation programs. One possibility would be raising the 1.25% deduction from
highway programs to 1.5% or more. Some MPOs also argue that providing more flexibility in the
use of federal planning funds, particularly those overseen by FHWA, would help them fulfill their
planning requirements. Another complaint is that MPOs cannot use all their apportioned federal
planning funds because they cannot raise the local matching share due to state and local funding
constraints.41 An option, therefore, might be to increase the federal share from the current 80%.
The downside of this approach is that it may not increase the amount of funds going to
metropolitan planning, because raising the federal share might result in less support from state
and local government. Another approach might be to increase FHWA and FTA technical support
to MPOs by helping with the challenges of modeling including acquiring the necessary data.
A different approach to the issue of MPO funding and technical capacity is to reduce the federal
requirements for metropolitan planning. This could be done in a number of different ways. One
approach would be to increase the population threshold for the creation of an MPO from 50,000
residents. The STAA, for instance, has proposed increasing the threshold to 100,000 residents,
although existing MPOs in areas currently between 50,000 and 100,000 would be maintained as
required by current law. The threshold for designating a TMA, with the added requirements for
MPOs, might also be increased from the current population of 200,000. Another option might be
to drop the requirements for developing long-range plans. Some have suggested that such
planning is a waste of time and money because, among other things, conditions 20 years in the
future are impossible to predict.42 Nevertheless, highways, transit systems, and other significant
infrastructure projects typically last much longer than 20 years, so it might be argued that it is
worth thinking through as much as possible the longer-term ramifications of such decisions.

40
Transportation Research Board, Metropolitan Travel Forecasting: Current Practice and Future Direction, Special
Report 288, Washington, DC, 2007, p. 6, http://onlinepubs.trb.org/onlinepubs/sr/sr288.pdf.
41
GAO, 2009, p. 17.
42
Randal O’Toole, 2009.

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MPOs and “Livability/Sustainability” Initiatives
An often heard criticism of federal surface transportation policy is that, over the years, it has
largely ignored the effects of transportation investment on urban land use development. Among
the transportation policies said to have contributed to these problems are the division of funding
into inflexible highway and transit “silos,” giving state DOTs almost complete control over the
large pot of highway funding, and ignoring the linkages with other federal policy areas such as
housing and the environment, particularly at the scale of the metropolitan region.43 Consequently,
federal support, as previously mentioned, is thought to be biased toward road building in rural
and newly urbanizing areas on the urban fringe, which begets more low-density residential and
commercial development that is difficult to serve with transit, and, therefore, contributes to more
car dependency and motor vehicle emissions.
The remedy, according to this argument, is to focus flexible transportation funding much more on
solving problems in metropolitan regions and to leverage the synergies between transportation,
housing, and environmental policies. Thus, for instance, federal policies could encourage states
and localities to provide for housing, densely formed with commercial development around
transit stations and stops. This would, according to its proponents, allow people to choose among
a number of ways of traveling—including automobile, transit, bicycling, and walking—to access
work, shopping, and other amenities. Such transit-oriented development (TOD) could also
provide new customers for transit agencies, reduce vehicle-miles traveled and the associated
environmental problems, and lower household transportation expenditures.
Proponents of this approach often include a greater scope for metropolitan transportation planning
and greater power for MPOs. The Obama Administration has announced an Interagency
Partnership for Sustainable Communities to be entered into by DOT, the Department of Housing
and Urban Development (HUD), and the Environmental Protection Agency (EPA). The
Partnership is designed “to help improve access to affordable housing, more transportation
options, and lower transportation costs while protecting the environment in communities
nationwide.”44 To “enhance integrated planning and investment ... HUD, EPA and DOT propose
to make planning grants available to metropolitan areas, and create mechanisms to ensure those
plans are carried through to localities.”45 Presumably, MPOs would be well placed to receive
those grants to enhance integrated planning.
From the brief descriptions available, the planning grants announced by the Obama
Administration do not appear to be much different than the intent of those available under a
program established in TEA-21 and continued in SAFETEA—the Transportation, Community,
and System Preservation (TCSP) Program.46 As enacted, the TCSP program provides relatively
43
U.S. Congress, House Committee on Appropriations, Subcommittee on Transportation, Housing and Urban
Development, and Related Agencies, Supporting Integrated Planning and Decision Making by Joining-Up Housing
and Transportation, Congressional Testimony of Robert Puentes, Brookings Institution, 111th Cong., 1st sess., March
19, 2009, http://www.brookings.edu/~/media/Files/rc/testimonies/2009/0319_transportation_puentes/
0319_transportation_puentes.pdf.
44
U.S. Department of Transportation, Office of Public Affairs “DOT Secretary Ray LaHood, HUD Secretary Shaun
Donovan and EPA Administrator Lisa Jackson Announce Interagency Partnership for Sustainable Communities,” Press
Release DOT 80-09, June 16, 2009, http://www.dot.gov/affairs/2009/dot8009.htm.
45
Ibid.
46
See U.S. Department of Transportation, Federal Highway Administration, “Transportation, Community, and System
Preservation Program website,” http://www.fhwa.dot.gov/tcsp/index.html.

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small discretionary grants for research and planning to states, MPOs, and local governments to
establish “a comprehensive program to address the relationships among transportation,
community, and system preservation plans and practices and identify private sector-based
initiatives to improve such relationships” (SAFETEA, Section 1117). Although FHWA
administers the program in cooperation with other DOT modal administrations and EPA, over the
life of the program, TCSP grants in most years have been awarded by congressional designation
(earmarks) in appropriations legislation. The exceptions to this were FY1999, FY2000, and
FY2007 when some or all of the program’s funds were allocated by the Secretary of
Transportation. Partly due to the way the program was originally conceived and partly because
most of the funds have been earmarked, the TCSP program has generally served as a pot of
funding to be used for almost any surface transportation purpose. Without a clear purpose, it is
difficult to evaluate the success of the projects being supported and the success of the program as
a whole. Similarly, it could be argued that without a clear understanding of what is meant by
“sustainability” and “livability,” the new planning grants might go for almost any purpose, and
the success or failure of funded projects difficult to judge. Congress might also be concerned with
the basis on which these new planning grants are to be distributed.
Despite the creation of this Interagency Partnership, moreover, it is not entirely clear without
legislation what mechanisms and funding these agencies have at their disposal to follow through
with sustainability/livability initiatives. FTA recently announced that it would use unallocated
New Starts/Small Starts Program funds ($130 million) and Bus and Bus-Related Facilities
Program funds ($150 million) to support its livability initiative, but again these program funds are
often earmarked by Congress. These relatively modest amounts of funds, moreover, are already
designated for transit.47 Surface transportation reauthorization, climate change legislation, or
both, therefore seem more likely sources of new authority and resources. In the reauthorization of
surface transportation programs, one transportation coalition is proposing that metropolitan areas
of 1 million or more, with smaller areas given the chance to opt-in, should be required to develop
what it calls 20-year Regional Blueprint plans which “demonstrate how proposed transportation
investments and system operations and management will coordinate with land use strategies to
achieve timely and reasonable progress towards meeting National Transportation Performance
Targets.”48 An aspect of developing the plans is land-use scenario planning. If enacted as
proposed, these plans would have to be approved by the state, DOT and EPA, and reviewed by
HUD and the Department of Health and Human Services. Once approved, an MPO would be
granted federal transportation funds and project selection authority.

Legislative Proposals
As noted earlier, STAA proposes to provide MPOs with federal funding directly. Moreover, the
bill adds some factors that an MPO would be required to consider in the planning process such as
enhancing sustainability and livability, reducing GHG emissions and dependence on foreign oil,
improving public health, and the relationship between transportation and land use development

47

U.S. Department of Transportation, Federal Transit Administration, “Exempt Discretionary Program Grants (Section
5309) for Urban Circulator Systems,” 74 Federal Register 234, December 8, 2009, pp. 64989-64994,
http://edocket.access.gpo.gov/2009/pdf/E9-29245.pdf; U.S. Department of Transportation, Federal Transit
Administration, “Section 5309 Bus and Bus Facilities Livability Initiative Program Grants,” 74 Federal Register 234,
December 8, 2009, pp. 64984-64989, http://edocket.access.gpo.gov/2009/pdf/E9-29242.pdf.
48
Transportation for America, 2009, p. 24.

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patterns. In many cases, STAA would require an MPO to develop performance measures and
strategies to meet the targets that are set.
Similar requirements are also included in various versions of climate change legislation that are
working their way through Congress. The House passed H.R. 2454 (Waxman/Markey) on June
26, 2009. A Senate version of the legislation, S. 1733, was introduced September 30, 2009. A
more limited bill, the Clean, Low Emission, Affordable, New Transportation Efficiency Act (S.
575/H.R. 1329), sometimes referred to as CLEANTEA, that supporters hope might be included in
a larger climate change bill proposes some transportation-related aspects of climate change
mitigation. Three common characteristics of the bills are a new fund that will receive money from
the auction of GHG emission allowances; requirements for states and MPOs responsible for
TMAs to develop GHG reduction plans; and the use of funds from the new fund to do the
planning and to implement projects in the plan. H.R. 2454 provides 1% of auctioned funds to be
used for transportation purposes, whereas S. 575/H.R. 1329 proposes 10% of these new funds.
One point of controversy has been whether the GHG emission reduction plans required as part of
the planning process must be submitted to and approved by the Environmental Protection Agency
instead of or in addition to the Department of Transportation. This provision was included in the
version of H.R. 2454 passed by the House Energy and Commerce Committee, but was
subsequently dropped in the version passed on the floor of the House. Environmentalists
generally favor EPA oversight with the view that this is most likely to result in stricter limits and
enforcement. In contrast, the transportation community generally opposes EPA oversight with the
view that EPA is likely to favor the environmental over the transportation goals of a plan, and that
the added oversight would result in longer approval time for projects.49
A different view on livability/sustainability initiatives, and the role that MPOs might play, is that
promoting denser, transit-oriented development through more transit funding and planning
regulations will result in smaller, less affordable housing and will actually inhibit mobility
through increased reliance on transit and more highway congestion.50 Trips by transit, analysts
propounding this view contend, are almost always slower than those in private vehicles, and
transit usage does not typically confer significant environmental benefits. Just as the greatest
success in battling urban air pollution has been through technical improvements, particularly the
catalytic converter, these analysts argue that reducing GHG emissions will not be done by getting
people out of their cars, but by getting them into plug-in hybrids and employing other “green”
technologies.51 Changing travel behavior, they argue, is an expensive way to reduce GHG
emissions and may potentially damage the economy by reducing the efficiency of regional
economies.

49
Adam Snider and Kate Naseef, “Transportation Stakeholders Fight Proposal To Shift Planning Authority From DOT
to EPA,” BNA Daily Report for Executives, June 1, 2009, pp. A-10.
50
Ronald D. Utt, President Obama’s New Plan to Decide Where Americans Live and How They Travel, Heritage
Foundation, Backgrounder, No. 2260, Washington, DC, April 14, 2009, http://www.heritage.org/Research/
SmartGrowth/upload/bg_2260.pdf; Randal O’ Toole, 2009.
51
Wendell Cox, “Regulating Greenhouse Gases, Not People: Opportunities and Possibilities,” Presentation, Heritage
Foundation, Washington, DC, July 23, 2009, http://demographia.com/dmgghgher.pdf.

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Climate Change Mitigation, Compact Cities, and Transportation
The arguments for and against more compact urban development and related policies, such as
greater transit funding, have taken on new urgency in the past few years because of the concern
with GHG emissions and climate change. As a whole, EPA says transportation was responsible
for 28% of all GHG emissions in the United States in 2007. Highway vehicles alone were
responsible for 23% of the U.S. total.52 Some analysts have argued that advances in vehicle
energy efficiency that reduce fuel consumption and fuel carbon content have been overwhelmed
by the growth in vehicle miles traveled. They argue that to reduce the amount of GHG from the
transportation sector it will be necessary to reduce vehicle miles traveled (VMT). To do that, one
school of thought argues “compact development will reduce the need to drive between 20 and 40
percent, as compared with development at the outer suburban edge with isolated homes,
workplaces, and other destinations.”53
A review of the evidence by a special study committee of TRB agreed that denser urban
development could reduce VMT. As it noted in the study report,
the literature suggests that doubling residential density across a metropolitan area might
lower household VMT by about 5 to 12 percent, and perhaps by as much as 25 percent, if
coupled with higher employment concentrations, significant public transit improvements,
mixed uses, and other supportive demand management measures.54

Even though substantial building of residential and commercial property will presumably take
place between now and 2050, doubling residential densities would be very challenging because
land use is controlled mostly by local jurisdictions, where existing residents are often very
concerned about new development causing congestion, higher property taxes, and the like. Thus,
the committee believes that reductions in VMT, energy use, and CO2 emissions resulting
from compact, mixed-use development would be in the range of less than 1 percent to 11
percent by 2050, although the committee disagreed about whether the changes in
development patterns and public policies necessary to achieve the high end of these findings
are plausible.55

Other Issues with Transportation Planning Requirements
Long-Range Planning
There are three other issues having to do with transportation planning requirements that Congress
may want to consider. The first of these is whether or not MPOs should be required to develop
52
Environmental Protection Agency, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2007, EPA 430-R09-004, Washington, DC, April 15, 2009, http://www.epa.gov/climatechange/emissions/downloads09/
InventoryUSGhG1990-2007.pdf.
53
Reid Ewing, Keith Bartholomew, and Steve Winkleman, et al., Growing Cooler: The Evidence on Urban
Development and Climate Change (Washington, DC: Urban Land Institute, 2008), p. 9.
54
Transportation Research Board, Driving and the Built Environment: The Effects of Compact Development on
Motorized Travel, Energy Use, and CO2 Emissions, Special Report 298, Washington, DC, 2009, p. 2,
http://onlinepubs.trb.org/Onlinepubs/sr/sr298prepub.pdf.
55
Ibid., p.4.

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long-range plans. Critics argue that for two main reasons Congress should not require long-range
plans, and should have MPOs focus on the short-term TIP instead. They contend that the
metropolitan planning process in most places is flawed because it does not follow a rational
planning model where alternative projects are weighed one against another with as many of the
benefits and costs measured as possible. Thus, the long-range planning process is dominated by
professional planners who often seek to change travel behavior by pursuing smart growth
solutions of compact development and by heavily subsidizing non-automobile modes of
transportation. The second main reason given for abandoning federal requirements for long-range
planning is that it “requires information about the future that is essentially unknowable.”56 This
includes things like the price of oil, the state of vehicle technology, job and housing location, and
the prevalence of telecommuting. Because much of the information necessary for long-term
planning is unknowable and because many of the costs and benefits are not quantified, this
critique insists that project decisions are typically made on political grounds rather than on
rational grounds. Instead, it is argued, metropolitan planning “should focus on the short term, give
transportation agencies incentives to improve transportation outcomes, and encourage regions and
agencies to rely more on user-fee-based funding mechanisms.”57

Freight Transportation
A second issue is the incorporation of freight transportation needs and concerns into the planning
process. One study has noted that there is no clear mandate for freight planning in federal law,
although it is included in Titles 23 and 49 as something that should be considered.58 Moreover,
the same study also notes that while the planning process is required to include public outreach
and participation, in many areas the freight community is not involved in the process in any
meaningful way. In places where there is involvement, often through freight advisory committees,
the concern is that this is not clearly linked to the development and prioritization of projects. For
these reasons, some suggest that freight plans be a required component of statewide and
metropolitan transportation plans. Another option is for the federal government to provide extra
funds to states and MPOs to hire staff freight experts.59

Geographic Scale
The freight problem is a good example of a third planning issue that could be of concern to
Congress, the geographic scale at which planning is undertaken and the integration of
metropolitan planning with planning being done at different scales. At the moment, metropolitan
transportation plans must be integrated with statewide transportation plans. Because travel,
particularly freight, often exceeds the jurisdiction of a single MPO or state, there have been calls
for developing a national transportation plan and multi-state freight corridor plans. The National
Surface Transportation Policy and Revenue Study Commission, for example, recommended the
56
57

Randal O’Toole, 2008, p. 22.
Ibid.

58
Cambridge Systematics, Prime Focus, and Kevin Heanue, Integrating Freight into Transportation Planning and
Project-Selection Processes, Transportation Research Board, National Cooperative Highway Research Program,
NCHRP Web-Only Document 112, Washington, DC, March 2007, http://onlinepubs.trb.org/onlinepubs/nchrp/
nchrp_w112.pdf.
59
Freight Stakeholders Association, “Association Stakeholders Call for National Freight Program and Stronger Federal
Role,” News Release, May 21, 2009, http://www.intermodal.org/stakeholders_files/documents/
PR_FSC_Call_for_National_Freight_Program.pdf#page=3.

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creation of a national strategic plan, 60 and AASHTO has suggested that Congress provide funding
for multi-state corridor planning and investment organizations, such as the I-95 Corridor
Coalition.61
Heeding these concerns, there have been legislative proposals for adding new transportation
planning requirements at the national, state, and regional levels. The STAA, for example,
proposes to create new requirements for the development of a National Transportation Strategic
Plan, state freight plans, metropolitan mobility plans, and freight corridor plans. The draft bill
allows funding to be provided to a maximum of ten freight corridor coalitions to develop the
freight corridor plans. A coalition would be comprised of representatives from state DOTs, MPOs,
port authorities, freight carriers, and shippers. Under the proposed legislation, the freight corridor
plan would be required to be consistent with the long-range statewide transportation plan, the
statewide improvement plan, the metropolitan long-range transportation plan, the transportation
improvement program, and the metropolitan mobility plan.
Alternatively, it could be argued that requiring these many different layers of planning could
consume an enormous amount of effort, time, and thus money, not only on each individual plan
but also on coordinating and making the different plans consistent. Moreover, in the case of
disagreements it might be difficult to determine which organization and which plan takes
precedence. The result, therefore, could be a stalemate that inhibits rather than promotes
transportation system improvements.

Conclusion
Since the end of the Second World War, America has experienced what one historian calls a
“metropolitan revolution,” in which the economy and culture of tightly drawn regions of urban
and suburban development each focused on a central core “was replaced by an amorphous sprawl
without a unifying hub or culture.”62 According to this view, an important dimension of change
has been the increasing fragmentation of metropolitan governance, as urban regions have
decentralized over larger and larger areas. For example, the metropolitan area of Pittsburgh, one
of the most fragmented, was estimated to have over 400 general-purpose local governments in the
late 1990s. Even the Phoenix metropolitan area, one of the least fragmented, was estimated to
have 34 local governments.63
Despite the amorphousness of contemporary urban development, research suggests that there is a
significant interdependence between places in a metropolitan area that bears on a region’s
economic efficiency and, thus, competitiveness in a national and international context.64
60
National Surface Transportation Policy and Revenue Study Commission, Transportation for Tomorrow, Washington,
DC, 2007, http://www.transportationfortomorrow.org/final_report/
61
AASHTO, Freight Authorization Policy, http://www.transportation.org/sites/policy_docs/docs/vi.pdf.
62

Jon C. Teaford, The Metropolitan Revolution: The Rise of Post-Urban America (New York: Columbia University
Press, 2006), p.3.
63
Myron Orfield, American Metropolitics: The New Suburban Reality (Washington, DC: Brookings Institution Press,
2002), p 132.
64
Andrew F. Haughwout and Robert P. Inman, “How Should Suburbs Help Their Central Cities? Growth- and
Welfare-Enhancing Intrametropolitan Fiscal Distributions,” The Annals of the American Academy of Political and
Social Science, vol. 626 (November 2009), pp. 39-52.

Congressional Research Service

18

Metropolitan Transportation Planning

Governmental fragmentation can make it particularly difficult to deal with problems of a regional
nature, such as transportation congestion, that affect metropolitan productivity. This is because, it
is argued, “planners and politicians are torn between mitigating the localized effects of regional
problems and addressing the common concerns and long-range interests of their larger
metropolitan areas.”65
Over the years there have been three main ways that regional governance in metropolitan areas
has been enhanced. 66 The first way is through the state-granted power of annexation by which
cities are able to expand into bordering developed or undeveloped unincorporated areas. For
example, between 1960 and 1990, Houston added 212 square miles to its jurisdiction, an increase
of 65%. A second way of reducing governmental fragmentation is through multijurisdictional
consolidation. This is typically done when a city consolidates with a county and the cities within
it. An example is the consolidation of the City of Indianapolis and Marion County that took place
in 1970. Although there has been some reduction in governmental fragmentation due to
annexation of territory and consolidation of local governments, in many states, particularly in the
older and more developed Northeast and Midwest, powers to annex and consolidate are weak.
The third main way that regional governance has been enhanced is the development of specialpurpose regional bodies, the most widespread of which are MPOs. Although regional authorities
sit uncomfortably in the long established intergovernmental system of federal, state, and local
government, strengthened MPOs might offer the most likely current means of reducing the
fragmentation of metropolitan governance. This may be a primary reason why some would like to
see Congress significantly enhance and broaden the authority and resources of MPOs now and in
the future.

Author Contact Information
(name redacted)
Specialist in Transportation Policy
[redacted]@crs.loc.gov, 7-....

65
66

Ibid., p. 130.
Ibid., pp. 133-140.

Congressional Research Service

19

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AR41068. Public record. Not legal advice.