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37.145  State comment on plans.

1. Was the plan filed on time?
2. Does the plan appear reasonable?
3. Are there circumstances that bear on the ability of the grantee to carry out the plan as represented?  If yes, please elaborate.
4. Is the plan consistent with statewide planning activities?
5. Are the necessary anticipated financial and capital resources identified in the plan accurately estimated?

As already discussed under §37.135, the states will receive UMTA recipient plans for section 18 recipients administered by the State or any small urbanized area recipient of section 9 funds administered by a state.  Public entities who do not receive UMTA funds will submit their plans directly to the applicable Regional Office (listed in Appendix B to the rule).

The role of the state is to accept the plans on behalf of UMTA, to ensure that all plans are submitted to it and forward the plans, with any comments on the plans, to UMTA.  This comment is very important for UMTA to receive, since states administer these programs on behalf of UMTA.  Each state's specific knowledge of UMTA grantees it administers will provide helpful information to UMTA in making its decisions. The rule lists five questions the states must answer when they forward the plans.  These questions are gauged to capitalize on the working knowledge the states possess on the grantees.  UMTA will send a more specific letter of instruction to each state explaining its role.