Multijurisdictional and Potentially Duplicative Applications
The Safe Streets and Roads for All (SS4A) discretionary grant program is focused on improving roadway safety for all users by reducing and eliminating serious injury and fatal crashes through comprehensive safety action plans (Action Plans) and their subsequent implementation.
This page describes how to proceed if you are applying as a multijurisdictional group of entities, as well as how the SS4A program will address overlapping and potentially duplicative applications.
- Multijurisdictional Applications for Planning and Demonstration Grants
- Multijurisdictional Applications for Implementation Grants
- Overlapping or Potentially Duplicative Applications
- Coordination with Other Entities
- Partnerships During Post-Award Administration
- Multijurisdictional and Duplicative Applicant Scenarios
Eligible applicants for SS4A grants are:
- A metropolitan planning organization (MPO)
- A political subdivision of a State or territory
- A Federally recognized Tribal government
- A multijurisdictional group of entities described in any of the aforementioned three types of entities
For the purposes of the FY23 SS4A Notice of Funding Opportunity (NOFO), a political subdivision of a State under (2), above, is defined as a unit of government under the authority of State law. This includes cities, towns, counties, special districts, and similar units of local government, as well as transit agencies created under State law.
A multijurisdictional group of entities should identify a lead applicant as the primary point of contact. Lead applicants are expected to be the entity primarily involved with administering the grant should an applicant receive an award on behalf of a multijurisdictional group. SS4A has no restrictions on rural and urban jurisdictions combining as a multijurisdictional group; the Department will consider multijurisdictional applications that combine rural and urban jurisdictions to be urban applicants. The term “joint applicant,” used during the FY22 NOFO, has been replaced in favor of “multijurisdictional group.”
The U.S. Department of Transportation (USDOT) encourages multijurisdictional partnerships for Planning and Demonstration Grants, particularly for the development of an Action Plan and supplemental planning activities. Applicants who have never received Federal funding and can apply with entities experienced in executing USDOT grants may find it beneficial to do so as well. It may be appropriate for eligible MPOs, transit agencies, or larger communities to assume the role of lead applicant to support subdivisions of a State such as cities, towns, and counties with smaller populations within their region.
In general, an MPO, county, or other regional entity applying for a Planning and Demonstration Grant will be assumed to be developing the plan for the entire area unless the application notes otherwise. The application does not need to list each individual municipality within the jurisdiction on the list of applicants. However, if the regional entity is applying on behalf of a select subset of municipalities to conduct a plan for a smaller area within the region, or to help facilitate the municipalities in conducting their own plans, then it would be appropriate to specify each of the municipalities as a multijurisdictional group of applicants.
USDOT expects that regionally focused Action Plans developed through SS4A grants will include sufficient detail and analysis to allow individual entities within that regional plan to apply for Implementation Grants in later funding rounds as standalone applicants.
The situations in which a multijurisdictional application for an Implementation Grant would be beneficial are different than for Planning and Demonstration Grants. Multijurisdictional applications for Implementation Grants may be appropriate in situations such as:
- Corridor and other project and strategy safety advancements that provide benefits to multiple communities;
- Multiple jurisdictions have ownership over the roadways where projects and strategies are to be executed;
- Multiple jurisdictions combine expertise to complete the projects and strategies; and
- Multiple jurisdictions combine experience with administering Federal grant requirements.
MPOs or other regional entities applying for a series of implementation projects and strategies across multiple jurisdictions should ensure that each project and/or strategy proposed is:
- Referenced in an existing Action Plan;
- Clearly connected to an identified safety concern; and
- An appropriate response to the identified safety concern that, to the extent practicable, is evidence-based and/or effective.
An eligible applicant may submit only one application to the funding opportunity (either a Planning and Demonstration Grant, or an Implementation Grant). In most cases, different offices within a jurisdiction would be considered as the same applicant (i.e., the public works, police, and planning departments within a jurisdiction cannot each apply separately). If an applicant submits more than one application, USDOT will consider only the application submitted most recently.
USDOT generally considers requests to fund multiple planning activities in the same area as duplicative. For example, municipalities applying to develop an Action Plan in an area where a higher-level jurisdiction (e.g., an MPO or county would be a higher-level jurisdiction for a city or town) has an existing plan in place or is in the process of completing an Action Plan, could be considered duplicative.
USDOT will identify duplicative requests and assess them for merit within the context of other jurisdictions and their planning and demonstration activities. Applicants must articulate the value or benefit of the duplicative application (e.g., opportunity for deeper analysis within the community, additional stakeholder engagement for groups not included during the initial Action Plan development, etc.), and affirm that they will coordinate where appropriate and possible.
However, USDOT encourages complementary but distinctive activities, including but not limited to demonstration activities that will help inform the development of an Action Plan. Implementation Grant and Action Plan Grant award recipients that received an FY22 award may apply for funding in FY23. USDOT may decline to fund duplicative applications irrespective of their individual merits.
Applicants are expected to coordinate with other entities (regardless of whether they are eligible applicants) to successfully implement their funded activities. For example, it may be appropriate to coordinate with entities such as the State DOT, local non-profit organizations, or neighboring jurisdictions that may have roadway ownership or maintenance responsibilities. While the NOFO does not specifically require applicants to list partners, it is recommended that the narrative reference appropriate partners if their participation is critical to the success of the project.
Implementation Grant applicants performing projects and strategies on a roadway that they do not own, maintain, or have safety responsibilities over must include, at a minimum, a letter of intent from the agency that has ownership and/or maintenance responsibilities for the roadway within the applicant’s jurisdiction (i.e., a letter of intent from the State if it is a State-owned road, etc.). If the application is awarded, a more formal agreement between the applicant and other relevant party would need to be in place prior to USDOT obligating funding to the grant award.
Any Memorandum of Understanding or other agreement required to successfully execute a grant agreement must be in place prior to USDOT signing a Planning and Demonstration Grant. or an Implementation Grant agreement.
SS4A grant agreements are directly between the lead applicant and USDOT.
In the case of multijurisdictional applications, the lead applicant is expected to manage all funding and administrative requirements.
A recipient may establish an arrangement separate from the USDOT grant agreement with a State DOT or another State or local governmental entity so long as that arrangement complies with State and local law. Under 2 CFR § 200.331, the recipient must determine whether such arrangement is contractual, such as an interagency agreement, or a subgrant. As provided at 2 CFR § 200.300(b), the recipient is responsible for compliance with all Federal requirements applicable to the award. The SS4A recipient would retain responsibility for ensuring completion of the grant activities and for compliance with the terms of the grant award and Federal requirements. Applicants may not serve as a pass through for a State DOT to take full responsibility over the grant agreement and States will not have direct funding relationships with USDOT.
The tables below summarize various scenarios and SS4A applicant options for local governments considering applying for their own grant versus submitting a multijurisdictional application with other local and/or regional entities, such as an MPO, council of governments (COG), or regional planning commission (RPC).
|Regional government (MPO, COG, RPC, large county etc.)||Local political subdivision within the same region (e.g., city, county, town, etc.)||Application options|
|Wants to apply for a Planning and Demonstration Grant to develop an Action Plan.||Also wants to apply for a Planning and Demonstration Grant to develop or complete a plan.||
|Has a qualifying Action Plan in place.||Wants to apply for a Planning and Demonstration Grant to develop an Action Plan.||
|Has a qualifying Action Plan in place or is in the process of completing an Action Plan.||Wants to apply for only Supplemental Planning and/or Demonstration Activities. Does not have its own Action Plan in place.||
|Received an FY22 Action Plan Grant award.||Wants to apply for only supplemental planning and/or demonstration activities. Does not have its own Action Plan in place.||
|Does not have a qualifying Action Plan in place and is not in the process of completing an Action Plan. Wants to apply for supplemental planning and/or demonstration activities through a Planning and Demonstration Grant.||Does not have a qualifying Action Plan in place and is not in the process of completing an Action Plan. Wants to apply for a Planning and Demonstration Grant to develop or complete an Action Plan.||
|Regional government (MPO, COG, RPC, etc.)||Local political subdivision within the same region (e.g., city, county, town, etc.)||Application options|
|Does not have an Action Plan in place. Would like to apply for a Planning and Demonstration Plan Grant.||Has a qualifying Action Plan in place. Would like to apply for an Implementation Grant.||
|Does not have an Action Plan in place. Would like to submit a multijurisdictional application with the political subdivision for an Implementation Grant.||Has a qualifying Action Plan in place. Would like to apply for an Implementation Grant via a multijurisdictional application.||
|Has a qualifying Action Plan in place. Would like to submit a multijurisdictional application with the political subdivision for an Implementation Grant.||Does not have an Action Plan in place. Would like to apply for an Implementation Grant via a multijurisdictional application.||
|Does not have an Action Plan in place. Would like to submit a multijurisdictional application with 10 political subdivisions for an Implementation Grant for multiple projects in the region.||
One political subdivision has a qualifying Action Plan in place. Would like to submit a multijurisdictional application for an Implementation Grant.
Other political subdivisions do not have an Action Plan in place. Would like to submit a multijurisdictional application for an Implementation Grant.
|Does not have an Action Plan in place. Would like to submit a multijurisdictional application with a group of political subdivisions.||Multiple political subdivisions have qualifying plans. Would like to bundle projects and strategies into one multijurisdictional application.||