By Nick Goldstein, vice president of regulatory and legal issues, ARTBA
ARTBA has made recommendations to streamline the regulatory process in a variety of areas as part of the U.S. Department of Transportation’s (USDOT) review of agency guidance documents.
Guidance documents are an agency’s way of interpreting their own regulations. In the case of the federal-aid highway and transit programs, they provide direction to the agencies’ offices around the country – as well as state and local transportation departments – in implementing those programs.
It is a rare for any agency to open up all of its existing guidance documents for review. Therefore, this was a unique opportunity for ARTBA and its members to weigh in with USDOT on multiple topics. After consultation with our members, ARTBA’s May 8 comments focused on guidance reform in these areas:
- Disadvantaged Business Enterprise (DBE) program
- “Buy America” rules
- Use of categorical exclusions (CEs)
- Federal Highway Administration (FHWA) fiscal constraint policies.
Now that the comments are filed, ARTBA will remain in a dialogue with USDOT to help turn our reform proposals into agency policy.