Other implementation impacts or considerations for FTA to address
FTA should divorce the definition of the federal project that is studied for NEPA purposes from the definition of the project used to determine the applicability of other statutory and regulatory requirements. This would pre-empt issues with segmentation that may arise from the flexibility offered under alternate federal project definitions.
FTA should consider how changing the definition of a federal project would allow grantees to reconcile conflicts between federal and state/local requirements and/or objectives. Examples include a state or local government wanting to give preference to local vendors for agency projects or the needing to follow FTA regulations.