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Lessons Learned in Coordinating OP-54 Readiness for Revenue Operations

Lessons Learned in Coordinating OP-54 Readiness for Revenue Operations. 2019 Capital Project Management Workshop. Lessons Learned in Coordinating OP-54 Review. Moderator Steve Truong, PE, PMP – Office of Capital Project Management Presenters

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Lessons Learned in Coordinating OP-54 Readiness for Revenue Operations

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  1. Lessons Learned in CoordinatingOP-54 Readiness for Revenue Operations 2019 Capital Project Management Workshop

  2. Lessons Learned in Coordinating OP-54 Review Moderator • Steve Truong, PE, PMP – Office of Capital Project Management Presenters • Erin Powell, PE, PMP – Regional Safety Officer, Office of Safety Review • State Safety Oversight & Major Capital Projects • Susan Ko, PE, PMP – Region IX, Office of Program Mgmt & Project Oversight • Gilbert Road LRT Extension • Cindy Moses, PE, PMP – Region VII, Office of Program Oversight • Kansas City Streetcar & St. Louis Loop Trolley • Cyrell McLemore, PMP, TSSP – Regional Safety Officer, Office of Safety Review • Milwaukee Streetcar 2019 Capital Project Management Workshop

  3. OP-54 Model • OP-22 & Circular 5800.1 Engineering ~2-3 years Construction ~5 years Project Development ~2 years LPA, Environmental Review, Tech Studies, & Preliminary Design Final Design, Critical Third-Party Agreements, PMP & Subplan, Safety & Security Review Construct System, Perform System Integration Testing & Start-up, and Conduct Pre-Revenue Operations, Safety Review OP-54 (~ 9 m before RSD) Revenue Service Pre-Revenue Operation, Rail Activation Plan, Completed Rule Book & SOPs, Operator & Maintenance Staff Training, Emergency Preparedness, Security System, Public System & Security Awareness, Spare Parts Requirements & Inventory Safety & Security Certification, Safety and Security Organization, Review of Safety and Security Planning, System Safety Program Plan (SSPP), Safety and Security Management Plan (SSMP), Collision Hazard Analysis, Operation Hazard Analysis, Grade Crossing Analysis, Threat & Vulnerability Analysis (TVA), Safety and Security Certification Plan (SSCP), Review of Risks and Mitigation, ROW Safety, Safety & Security Program, Management & Certification Plans, Certifiable Items List, Workarounds, Construction Punchlist System Integration Testing 1 2 3 LEGEND Key Review / Decision Point Safety & Security Oversight Process Design Conformance Review Operation Readiness Verification Final Safety & Security Certification Construction Specification Conformance Review Project Sponsor Integrated Test Safety & Security Monitoring FTA/PMOC SSOA

  4. State Safety Oversight & Major Capital Projects Erin Powell, Regional Safety Officer Office of Transit Safety and Oversight Federal Transit Administration 202.366.2164Erin.Powell@dot.gov

  5. Agenda • TSO Organizational Structure and Mission • SSOA Program Basics • Coordinated Capital Project Safety Oversight

  6. TSO Organizational Structure and Mission

  7. TSO Functional Chart

  8. Office of Transit Safety and Oversight (TSO) • Office of System Safety • Drives continuous improvements in transit safety through the implementation (internal and external) of Safety Management System (SMS) methods and principles • Office of Safety Review • Manages the Drug and Alcohol Program, State Safety Oversight (SSO) for rail transit, and Emergency Management • Office of Program Oversight • Administers a comprehensive program of oversight reviews to assess FTA grant recipient compliance

  9. Three-Year Audits • Three-year audits are not the same as FTA’s Triennial Reviews • Different criteria – legal, financial, technical • Different standards – beyond 5329 • Different division within TSO

  10. SSOA Program Basics

  11. Federal and State Organizational Structure for State Safety Oversight

  12. Federal and State Organizational Structure for State Safety Oversight • Federal Authority: MAP-21(P.L. 112-141) and further defined in SSO Final Rule (49 CFR Part 674) • Must: Oversee implementation of State Safety Oversight Agency (SSOA) program • Has Authority to: • Assume direct safety oversight and permit use of that SSO’s grant funds during the corrective time frame • Issue directives • Issue restrictions or prohibitions on operations at unsafe transit agencies • State Authority: State Law or Similar Vehicle and explained in each state’s Program Standard • Must: Review, approve and enforce Public Transportation Agency Safety Plan (PTASP) • Has Authority to: • Investigate and enforce safety on the rail transit system • Dictate how/when/oversight is completed, including Oversight of Projects (New)

  13. What the SSOA Must DO • Every state must establish a State Safety Oversight program and must ensure that the SSOA: • Has investigative and enforcement authority with respect to the safety of the rail transit system • At least once every three years, audits every system’s compliance with safety plan requirements • At least once a year, reports the status of the safety of each system to the Governor, the FTA, the board of directors, or equivalent agency

  14. SSO Program Changes • SSO Final Rule (49 CFR Part 674) replaced the existing SSO rule at 49 CFR Part 659 • States assume greater responsibility for overseeing the safety of their rail fixed guideway systems. • FTA reviews and approves each State’s SSO Program Standard, certifying whether States are meeting the statutory criteria. • FTA can impose penalties on those States with non-existent or non-compliant safety oversight programs. • Strengthens an SSOA’s authority to investigate accidents and oversee a rail transit agency’s implementation of its System Safety Program Plan (SSPP) and Public Transportation Agency Safety Plan (PTASP).

  15. State Safety Oversight Requirements • Regulations • 49 USC 5329(e)(2)(b) requires that the SSOA oversee “a rail fixed guideway public transportation system in the engineering or construction phase.” • Part 674.7 - Rail fixed guideway public transportation system: • Any fixed guideway system that uses rail, is operated for public transportation, is within the jurisdiction of a State, and is not subject to the jurisdiction of the Federal Railroad Administration, or any such system in engineering or construction.

  16. State Safety Oversight Responsibilities during Design and Construction • Under Part 674, SSOAs should be involved during design and construction of new systems or extensions • SSOA program standards should reflect the requirements for new systems and extensions • SSOA should be aware of the federal Project Management Oversight for: • Awareness • Coordination • Certification (if required)

  17. Coordinated Capital Project Safety Oversight

  18. Major Capital Project Coordinated Oversight • FTA Office of Program Management (TPM) of Federally Funded Projects • FTA Office of Transit and Safety (TSO) • SSOA Responsibilities in New Systems & Extensions

  19. Safety Oversight • Federally Funded Oversight - PMO Program Oversight Procedures (OPs) • Guidance provided by FTA for use by its PMOCs in performing oversight of major capital projects. • There are over 30 different oversight reviews • Two of the oversight reviews look at safety • OP-22 Safety and Security Management Plan Review (SSMP) • OP-54 Readiness for Revenue Service Review • What is included in State Safety Oversight? • Whatever is included in the Program Standard • Whatever is included in the Agency Safety Plan • Every State is different • Every Agency Safety Plan (ASP = SSPP or PTASP) is different

  20. Revenue Service for New Projects Difference Between Oversight Reviews TSO is no longer performing SSRRs

  21. LESSONS LEARNED IN COORDINATING OP-54 READINESS REVIEW Gilbert Road LRT Extension Project Susan Ko, General Engineer FTA Region IX

  22. LESSONS LEARNEDIN COORDINATING OP-54 REVIEW: Gilbert Road LRT Extension ADOT SSO Program Standard Highlights Project Overview FTA/PMOC/SSOA Coordinated Review Experience Lessons Learned 2019 Capital Project Management Workshop

  23. Gilbert Road LRT ExtensionADOT SSO Program Standard Highlights • ADOT SSO Program (SSOP) – Certified and Adopted on April 24 2018 • ADOT System Safety Program Standard for Rail Safety & Security Oversight: • Design Phase • Construction Phase • Pre-revenue Operation Phase • Testing, Start-up, and Training Phase • Safety and Security Certification Verification Report (SSCVR) Review & Acceptance • Project Turn-over Phase 2019 Capital Project Management Workshop

  24. Gilbert Road LRT Extension Project Overview Located in Mesa, AZ 2-mile Center-running Double Track LRT Extension 2 New Stations with an end-of-line P&R Facility, a New Roundabout Intersection 3 New Vehicles Budget: $186 Million, a non-NS Funded, 95% CMAQ/STP Flex Funds Major Construction: October 2016 – February 2019 Extension Opened for Revenue Operation on May 18, 2019 2019 Capital Project Management Workshop

  25. Gilbert Road LRT ExtensionFTA/SSOA Coordinated Review Experience • An Expedited OP 54 Review • Planning an Effective and Efficient Review with a Clear Understanding of the State Safety Oversight’s On-going Readiness Review • Goal of the Review – Focus Areas • System Integration Testing (SIT) – High Level Review & Verifying SSOA’s Process • System Safety and Security Validation- High Level Review & Verifying SSOA’s Process • Pre-Revenue Operation – High Level Review & Verifying SSOA’s Process • Management Capacity and Capability (MCC) - Detailed Review, Leveraging Sponsor’s Successful Processes. • Operation Hazard Analysis (OHA) Review/Walk-through 2019 Capital Project Management Workshop

  26. Gilbert Road LRT ExtensionLessons Learned • Start as Early as Possible • Appropriate Subject Matter Expertise PMOC Staff and Availability • Experience in System Safety/Security & Transit Operations • Close Agencies Coordination - SSOA, Valley Metro, and City of Mesa • Know the Redundancies and Work Closely with SSOA and Others to Verify the Redundant Processes 2019 Capital Project Management Workshop

  27. Gilbert Road LRT Extension “Not only does it provide options for our residents to reach important destinations, it has resulted in $240 million of completed economic development projects with more on the way,” said Mesa Mayor John Giles. Thank you! 2019 Capital Project Management Workshop

  28. LESSONS LEARNEDIN COORDINATING OP-54 REVIEW: Region VII Projects - KC Streetcar - St. Louis Loop Trolley Cindy Moses, Regional Engineer FTA Region VII

  29. Kansas City Streetcar • Scope: Modern Mixed Traffic Streetcar Starter Line • Cost: $110M Total Cost (20M TIGER/17M Formula) • Revenue Service Date: May 2016 • TIGER grant award - 2014 • Construction Substantially Complete – Nov 2015 • 6 months for Start Up, Testing, Pre-Revenue Operations • OP-54 report completed in Hold Points • Grantee: City of Kansas City, Missouri • New FTA grantee • Non-traditional grantee - partnership with KCATA (Regional Bus System) and KC Streetcar Authority (KCSA) (non-profit) 2019 Capital Project Management Workshop

  30. St. Louis Delmar Loop Trolley • Scope: Historic Mixed Traffic Streetcar Starter Line • Cost: $54M Total Cost (25M Urban Circulator/17M Formula) • Revenue Service Date: Partial November 2018, Full TBD • Urban Circulator Grant awarded - 2013 • Construction Substantially Complete – Nov 2016 • 2 years for Start Up, Testing, Pre-Revenue Operations (Time frame of OP-54 report) • Grantee: Loop Trolley Transportation Development District - New FTA Grantee • Non-traditional grantee • Loop Trolley Company (Non-profit) is the operator 2019 Capital Project Management Workshop

  31. OP-54 vs MoDOT SSO Role In Determining Project Readiness • OP-54 – Project Documents (per paragraph 5.1) • Project Scope • System Integration Testing • Safety and Security • Pre-Revenue Operations • Management Capacity and Capability • MoDOT SSO’s Program Standard Requirements • Involvement of the SSO in the design and construction of a new rail project or extensions • Pre-Revenue Service Review (PRSR) 60 days before opening (not all SSO’s require this) 2019 Capital Project Management Workshop

  32. RSOT Process • Multiple reviews looking at the same documents • 3 oversight reviews related to the project being ready for carrying the public - SSRR, OP-54, and MoDOT SSO’s Pre-Revenue Service Review (PRSR) • All look at the PMP, SSMP, SITP, O&M plan, rule book, training program, PHA, TVA, SSCP, CIL, RAP, SOPs, SSCVR • Burdensome effort for grantee • Conflicting comments or comments not aligning, between the oversight agencies creating frustrations for project sponsors - HYPOTHETICAL EXAMPLE “The SSMP was fine for the PMOC so why are you taking issue with it for the PRSR?” • Started the Revenue Service Oversight Team (RSOT) forum to coordinate the OP-54 review with the MoDOT SSO’s oversight requirement of a PRSR • Biweekly RSOT calls, coordinated comments before sending to the grantee, joint reviews and workshops were combined with quarterly meetings 2019 Capital Project Management Workshop

  33. Lessons Learned • Close coordination with SSO is critical. It is a PARTNERSHIP. • The timing of the OP-54 is during the phase between construction completion and revenue service. The importance of this project phase is often underestimated by all parties. • 6 months to multiple years in duration and can make or break project schedules and budgets. • Local sponsors and the public are eager to start when they see trains running and construction complete. • It’s a key staffing transition time – construction contractors, design consultants are transitioning off the job if not properly scoped through this phase new operations staff starting. • Non traditional or new FTA grantees make OP-54 review more challenging. • Starter systems vs an extension make OP-54 review more challenging. • Non CIG project make the OP-54 review more challenging. 2019 Capital Project Management Workshop

  34. Questions That Came Up • Who approves a new major capital project to start carry passengers? Who has the final Go/No Go responsibility? • How does the OP-54 report impact FTA decision making? SSO decision making? • What should be done when the OP-54 report identifies significant problems or risks for a project to start carrying the public? 2019 Capital Project Management Workshop

  35. Future Considerations • Review and update OP-54 and all OP’s with respect to the new SSO’s requirements. • OP-22 SSMP requires PMOC role in original SSMP, follow up review and adherence reviews • Look at the role that FTA Circular 5800.1 (dated August 2007) has in the current SSO environment. • PMOC’s and Regional Engineers should make sure the SSO is involved in project meetings and the review of documents early in the project oversight. • The PMP should not be approved without SSO’s input into the SSMP subplan. • During MCC reviews - the project organization chart should have the SSO’s input in making sure the safety function is meeting Part 674 requirements of reporting directly to the Accountable Executive. • OP-54 can be a valuable tool in determining overall project readiness but how does FTA use this tool going forward. The SSO doesn’t look at project aspects outside of safety. • Did the project scope meet the requirement of the FTA grant? • Doesn’t look at ADA, Civil Rights, Buy America, financial capacity, management capacity, public outreach, operational readiness, etc. 2019 Capital Project Management Workshop

  36. LESSONS LEARNEDIN COORDINATING OP-54 REVIEW: Milwaukee Streetcar Cyrell McLemore, General Engineer Office of Transit Safety and Oversight FTA Region V

  37. Milwaukee Streetcar The Project Project Partners Challenges Recommendations 2019 Capital Project Management Workshop

  38. The Project • Phase II • $28M • .77 Miles • 3 Stations • 1 Streetcar • Dec 2020 Phase I $99M 2.1 Miles 17 Stations 4 Streetcars Nov 2018 2019 Capital Project Management Workshop

  39. Project Partners • City of Milwaukee • FTA • Region V / PMO Partnerships • TSO • WI SSO • TRA • SSO Certified July 25, 2018 • Program Standard 2019 Capital Project Management Workshop

  40. Challenges • Funding • Non-Traditional Grantee • FTA Region: Staff Turnover • Coordination / Communication / Collaboration • FTA: OP-54 • WI SSO Provided Comments • WI SSOA: Pre-Revenue Service Review (PRSR) • Submitted w/Annual Report to TSO 2019 Capital Project Management Workshop

  41. Recommendations • Pre-Assessment of SSOA • Technical Capacity on Projects • Coordination/Communication/Collaboration • SSO/Region/TPM/TSO • Determine areas where safety oversight overlap can be reduced • Non-CIG Funding • OP-54 • Assess experience of Grantee & SSOA • Flexible to reflect Level of Effort • Concurrent Review w/SSO PRSR 2019 Capital Project Management Workshop

  42. QUESTIONS? 2019 Capital Project Management Workshop

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