G.B. Arrington - Comments

. In establishing the criteria that projects must “Provide a fair share of revenue that will be used for public transportation” FTA is stepping on to a very slippery slope. FTA should go back to the established criteria and also allow enhanced ridership as an alternative to fair share. The devil really is in the details: take two regions (Washington and the Twin Cities) and you get different answers on fair share between them. Drill down within a region what is fair will vary considerably. Add desired outcomes to the equation - what is fair in MSP where they are linking transit & affordable housing may be different than fair in Washington with decades of market experience with JD and a different value premium from transit accessibility. What is a fair share within the regions for different types of projects – an affordable housing v a market rate project? Commercial or residential? What is a fair return where the project sponsor is seeking to push the market further than it would otherwise go in terms of achieving transit-oriented development principals? The range of project types, public policy objectives, relative location within a region and the value of transit are the simply reality that goes into determining fair share in JD as policy makers seek to get good outcomes. How does FTA arbitrate? Where will you get the expertise? How will you do that in a timely manner essential for development projects? Establishing the criteria that projects must “Provide a fair share” is going to be subjective with all kinds of mitigating factors. That will make FTA's job as a good partner in JD with real world developer timelines all that more challenging. The criteria makes the job of local JD more difficult, it gets in the way of achieving DOT’s livable communities outcomes and it puts FTA in the difficult situation of trying to administer a program using a criteria subject to broad interpretation between and with regions.