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<br />o. <br /> <br />THOMPSON COBURN LLP <br />1909 KSnEET, N.W., Sum 600 <br />WASHINGTON, D.C. 20006-1167 <br />TELEPHONE 202-585-6927 <br />FACSIMILE 202-508.1012 <br />I!Gn.L@THOMPSONCOBURN.COM <br /> <br />Memorandum <br /> <br />Via Facsimile <br /> <br />FROM: <br /> <br />Tim Yantos <br />Mary ~s1f <br />Ed Gill ~ <br /> <br />TO: <br /> <br />DATE: <br /> <br />February.261 2008 <br /> <br />R.E: <br /> <br />Additional Stations: Northstar Project <br /> <br />)b. <br />. "J <br />:!,1. ~- <br /> <br />Per your requestl on. February 251 I spoke to Scott Biehl (Deputy Chief. Counsel of FT A) <br />concerning FTA's requirements/procedures applicable :to. a situation wherein an additional <br />station is added to the scope of a project governed by a Full. Funding Grant Agreement {FFGA}. <br />He offered the follo~ information: <br /> <br />1. If purely local money is used for an additional station or stations, there is no change <br />in the scope of the FFGAi FTA approval is not necessary; and Congressional notification is not <br />required. <br /> <br />2.. If Federal money is used (regardless of SOurce)1 a revision to the scope of the FFGA <br />would be required (obviously with FTA approval) and the th.irtyday Congressional notification <br />process for scope changes would be triggered. Howeverl he did indicate that none of the other <br />New Starts pro~sses would be triggered (e.g'l a neW CEI number}. <br /> <br />3. Under scenario 2 abovel no further environmental work would be required if the new <br />station was included in the' EIS for the over-all project. If not, he opined that some <br />environmental up-date would be required but that adding a commuter rail station usually does <br />not trigger a significant environmental review. <br /> <br />4. If a new station is added to a line after the initial work under an FFGA is completedl <br />he indicated that the full New Starts process would not be triggered ifl in facti the Federal share <br />of such. an activity was less than $25M. Such a project would be exempt under the existing <br />regulations. Note that under the proposed New starts regulations (currently on <br />Congressionally-mandated hold) a "very small siartsll program would be established, and <br />would govem the under $25M projects. However, until the regulations are finalizedl the <br />exempt projects category is still in play. <br /> <br />Chicago <br /> <br />St. Louis <br /> <br />Southern Illinois <br /> <br />Washington, D.C. <br /> <br />-50- <br />