On May 21, 2013, the Office of Inspector General of the U.S. Department of Transportation provided an update to Congress on the Moving Ahead for Progress in the 21st Century Act (MAP-21), requiring the Acceleration of Project Delivery (Subtitle C).  MAP-21 is the first long-term surface transportation authorization since 2005 and provides for $105 billion for 2013-2014.

In the letter, Joseph Come, Assistant Inspector General for Highway and Transit Audits, comes to the following conclusion:

While most of the Department’s remaining Subtitle C actions are in progress, a lack of completion dates for some actions combined with delays in some rulemaking actions could impede the Department’s ability to complete Subtitle C provisions in a timely manner.

This was the first review of a series of audits to assess DOT’s progress in implementing MAP-21’s project delivery reforms.  The DOT developed a plan with 42 actions to meet Subtitle C requirements, and most of these actions involve environmental issues that occur during the planning and design phase of highway projects.  According to the audit, the DOT completed only five of the actions and 34 were underway.  Three planned actions had not started, including: (1) establishing a best practices clearing house related to accelerated project delivery; (2) developing guidance on integrating planning and environmental reviews; and (3) reporting on the types of and justification for additional categorical exclusions.  The DOT stated that it has not begun these three actions because other actions either have a higher priority or need to be completed before it can start these actions.

So what?  Although the report goes into detail about the planned actions and target milestones, and goes as far to conclude that the DOT will be "challenged to complete required rulemakings by the statutorily set dates," there is little insight on the impact of delays in the implementation of MAP-21.  For example, what is going to be the practical effect of delays to new projects?  When will we see benefits of streamlined processes?  We understand that "timely completion of planned actions would help States and others managing Federal projects to fully realize the benefits of MAP-21’s innovation and streamlining provisions," (as noted in the report), but where is the accountability?  Maybe that is to come from the next audit?