FTA should not require all Federal requirements to apply to the entire project if any portion or phase of a project receives Federal funding
The FTA should apply federal requirements only to those parts of a project that receive federal funds and/or required local match. Removing the federal requirements on the local (non-match) portion of an otherwise federally funded project would streamline both the procurement process and overall project administration, and could result in cost and schedule savings.
There can be a cost to federal compliance. For example, meeting federal procurement requirements can increase project costs because the requirements restrict the grantee’s flexibility in setting specifications, sourcing vendors, and satisfying content requirements.
In terms of project delivery, a grantee’s ability to fulfill all federal requirements can add to procurement time, and may not always coincide with the need to begin project work. Some federal requirements increase the project timeline by adding approvals that involve multiple agencies at the state and federal level, particularly where the review and approval is redundant. Further, compliance with listing on STIP, Project Management Plans, force account plans, etc., require time that may not be an option when trying to meet project schedules.
Adherence to federal requirements for an entire project also makes it impossible for agencies to utilize locally funded and non-federally procured consultants that may perform work on several contracts (some federal, some non-federal). Imposing federal requirements on these sorts of contracts would limit the available pool. Having to conduct separate, federal procurements for consultants to complete limited federal scope adds time, unnecessary cost, and ultimately restricts flexibility of the grantee to apply the resources it has available most efficiently.