CHAPTER 2
Literature Review

This document summarizes a review of the existing literature, federal legislation and regulations, agency guidance, and other sources concerning state department of transportation (DOT) practices for transportation planning in non-metropolitan areas. The purpose is to identify and document effective practices, strategies for engaging non-metropolitan communities, and common challenges in the planning and project development processes. Relevant documents were identified through a combination of online searches [including a well-known search engine and Transport Research International Documentation (TRID)], academic library resources, targeted reviews of reports from the National Association of Development Organizations (NADO) Research Foundation, state DOT manuals, and federal regulations.

The review describes the current state of knowledge and practice on how state DOTs engage in transportation planning in non-metropolitan areas, with a focus on their coordination with a range of local and regional participants. These include federally designated Regional Transportation Planning Organizations (RTPOs), regional planning entities (RPEs) or their equivalent, rural transit providers, and non-metropolitan local officials with transportation responsibilities. Due to the federalist structure of government in the United States, states have developed a variety of organizational models and terminology for rural planning. As a result, terms such as RTPO, RPE, and other acronyms are used throughout this report to reflect state-specific practices. These terms are defined in context and further explained in a later section to clarify similarities, differences, and functional roles across states. The review also highlights the legislative framework that has shaped these practices, and the outreach methods used to engage non-metropolitan communities. See the “References and Bibliography” section of this report for a full list of sources consulted.

Defining “Rural” and “Non-Metropolitan”

The terms “urban,” “rural,” “metropolitan,” and “non-metropolitan” are defined differently across federal and state regulations, with variations depending on the context and purpose of the classification. The U.S. Census Bureau, for example, classifies areas as urban or rural based on population and housing unit density. Under the most recent classification from the 2020 Census, rural areas include open land and settlements with fewer than 2,000 housing units or 5,000 residents, while urban areas exceed these thresholds (Sanders and Cromartie, 2025; U.S. Census Bureau, 2024).

The Office of Management and Budget (OMB) defines metropolitan and non-metropolitan areas based on county-level economic and social integration rather than population density alone. Metropolitan areas include central counties with urban areas of 50,000 or more residents, along with outlying counties that have strong commuting ties to these central areas. Non-metropolitan

areas fall outside of metropolitan boundaries and are further classified as “micropolitan areas”—which are centered around urban clusters of 10,000 to 49,999 people—or noncore counties, which lack a central urban hub (OMB, 2021). This classification reflects broader labor-market relationships rather than strictly reflecting population size or settlement patterns. This metropolitan classification is also used by the U.S. Census Bureau for statistical purposes.

Federal law, as expressed through the United States Code (USC), directs the Federal Highway Administration (FHWA) to use the U.S. Census Bureauʼs definitions of rural and urban but allows some adjustments to better suit transportation planning needs. Specifically, for areas with a population over 5,000, FHWA can expand the urban area boundaries beyond what the Census defines, if needed. These expanded boundaries must include the entire Census-defined urban area and can also include additional areas that feel urban but donʼt meet the Censusʼs population requirements (like certain industrial or commercial areas). All areas not included in these adjusted urbanized areas are considered rural (Title 23 USC § 101).

Also defined under 23 USC, urbanized areas with populations over 50,000, as determined by the U.S. Census Bureau, are designated as metropolitan planning areas (MPAs) and are required to be represented by a metropolitan planning organization (MPO). Further, per Title 23 of the Code of Federal Regulations (23 CFR) Part 450, § 450.312, MPA boundaries must, at a minimum, include the entire Census-defined urbanized area and the surrounding area expected to become urbanized within a 20-year forecast period. These boundaries are established by agreement between the MPO and the Governor and may be further expanded to align with a metropolitan statistical area or reflect broader regional planning goals, such as economic development and multimodal connectivity. A geographic area outside of a designated MPA is considered to be a non-metropolitan area (Title 23 USC § 134).

Historical Context and Legislative Framework

In the early decades of modern transportation planning in the United States, rural voices were largely absent, even though rural infrastructure, from farm-to-market roads to freight corridors, was a major focus of state and federal investment. Early planning efforts by state DOTs were often centralized and top-down, with minimal engagement from local rural stakeholders, resulting in decisions that did not always reflect the specific needs and priorities of non-metropolitan areas (Frank and Reiss, 2014). As the planning process evolved, particularly following the introduction of the Continuing, Cooperative, and Comprehensive (3C) process in the 1960s and 1970s, more attention shifted toward urban areas to address growing population densities, economic development, and congestion. This transition coupled with the initial lack of meaningful rural participation, led to transportation solutions that frequently failed to address the unique conditions in non-metropolitan areas, such as long travel distances, limited public transportation options, and a reliance on freight for economic vitality (Frank and Hibbard, 2017; Frank and Reiss, 2014).

The limited influence of rural voices in the planning process can also be attributed to the complexity of aligning statewide policies with the localized needs of rural communities. Rural areas often lacked the institutional capacity and technical expertise required to fully participate in state-led planning processes, further exacerbating their underrepresentation (Dabson, 2020). Consequently, transportation projects in rural regions were sometimes characterized by inadequate infrastructure investments, limited multimodal options, and insufficient connectivity to larger metropolitan areas, affecting both economic opportunities and quality of life for rural residents (Frank and Hibbard, 2017).

In recent years, there has been a growing recognition of the multifunctional roles of rural areas, not only in terms of agriculture but also in addressing critical global challenges such as changing environmental conditions, water supply, and food production (Holmes, 2006; Gómez-Limón et al., 2012; Stauber, 2001; Frank and Reiss, 2014). However, the impacts of globalization have exacerbated rural struggles, as these areas have been increasingly tasked with providing resources to global systems while grappling with the extraction of people, resources, and economic opportunities (Frank and Hibbard, 2017).

Driven by the need to address these long-standing gaps in rural transportation planning and the desire to ensure that federal transportation funds were being used fairly and effectively across all regions, not just urban areas, state DOTs began making concerted efforts in the 1990s and 2000s to improve consultation practices with non-metropolitan officials. These reforms were, in part, driven by federal mandates that required increased consultation between state DOTs and rural stakeholders.

ISTEA, TEA-21, and MAP-21

The passage of the Intermodal Surface Transportation Efficiency Act (ISTEA) in 1991 and the Transportation Equity Act for the 21st Century (TEA-21) in 1998 marked milestones in U.S. transportation policy for rural areas. Both acts aimed to improve the transportation planning process by increasing the involvement of communities, particularly rural areas, that had previously had limited input in state DOT planning efforts. They laid the groundwork for improved relationships between state DOTs and rural communities by mandating outreach and consultation with local officials responsible for transportation during the development of state transportation plans.

ISTEA introduced the concept of consultation in transportation planning, encouraging increased communication with local governments, including those in rural areas. The law required states to consult with local officials outside of metropolitan areas, ensuring that rural transportation needs were considered. However, there were no specific requirements for the form or frequency of these consultations, and the extent of rural involvement varied across states (Schweppe, 2001; ISTEA, 1991).

TEA-21 built upon ISTEAʼs framework by reinforcing the role of rural local officials in statewide transportation planning. It encouraged states to enhance their consultation efforts with non-metropolitan officials, promoting more meaningful and systematic engagement in the planning process (Doyle et al., 2005). While TEA-21 stopped short of mandating a uniform approach to rural consultation, federal policymakers recognized the value of leveraging existing regional organizations, such as Regional Development Organizations (RDOs), as potential intermediaries to facilitate rural participation. As Doyle et al. (2005) note, this reflected a deliberate effort to strike a balance between federal encouragement and state flexibility, elevating the voice of rural officials without imposing rigid structural requirements.

Since then, a series of reauthorization acts, including the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) in 2005; the Moving Ahead for Progress in the 21st Century Act (MAP-21) in 2012; the Fixing Americaʼs Surface Transportation (FAST) Act in 2015; and the Infrastructure Investment and Jobs Act (IIJA) in 2021, have incrementally refined the relationship between state DOTs and rural communities. These laws introduced adjustments to how states engage with non-metropolitan areas, ensuring that rural voices would play a larger role in transportation planning.

MAP-21, in particular, marked a significant legislative shift in the approach to rural transportation planning by emphasizing the need for deeper involvement of rural officials. Prior to its

passage, federal regulations required state DOTs to “consult” with local officials with transportation authority in non-metropolitan areas, which often resulted in a limited, advisory role for these rural entities. While rural officials were engaged in the planning process, they often lacked meaningful influence over transportation decisions affecting their communities. This consultation-based model, though useful, was viewed by many as insufficient for fostering genuine collaboration between state agencies and non-metropolitan localities (NADO, 2025a).

MAP-21 introduced a policy change by replacing the term “consultation” with “cooperation” when describing the relationship between state DOTs and local officials. According to 23 CFR Part 450 Subpart A, “consultation” refers to a process in which one or more parties confer with other identified parties and, prior to taking actions, consider their views and periodically inform them about decisions made. In contrast, “cooperation” requires the involved parties to work together to achieve a common goal or objective. This change elevated the expected role of non-metropolitan officials in statewide transportation planning by requiring state DOTs to engage them more directly and work jointly toward shared outcomes. This change aimed to ensure that the distinct needs and priorities of non-metropolitan areas were more fully integrated into the statewide planning process.

Although MAP-21 was authorized for 2 years (FY 2013–2014), its planning principles, including the enhanced role of non-metropolitan stakeholders, were carried forward under the FAST Act. The implementing regulations under 23 CFR Part 450 were not updated during MAP-21ʼs tenure; however, a comprehensive rulemaking process culminated in a final rule published in 2016, during the FAST Act era. This rule formally codified MAP-21ʼs planning reforms, including the shift from consultation to cooperation, and established a phased implementation timeline extending through 2018. During the interim time period, non-metropolitan planning entities and state DOTs continued to operate under SAFETEA-LU-era regulations, supplemented by interim guidance from the FHWA and the FTA. As of 2025, 23 CFR reflects planning rules primarily based on FAST Act provisions, as updates to incorporate IIJA requirements are still forthcoming. Because the regulatory process often lags behind new legislation, it is important that practitioners consult both the USC and the CFR. The USC contains the enacted statutes and is updated more quickly, while the CFR provides the corresponding implementation guidance. In instances where new laws have been passed but implementing regulations have not yet been updated, the USC governs. For example, IIJA provisions codified in 23 USC § 133(h) continue support for the Transportation Alternatives Set-Aside and add new requirements for states with RTPOs under 23 USC § 133(h)(7), including enhanced planning capacity, technical assistance, and access to discretionary funds. IIJA also established new programs such as the Rural Surface Transportation Grant Program, which expands funding and planning opportunities for RTPOs and rural jurisdictions.

These shifts in language and policy reflect a broader evolution in the expectations for rural participation in transportation planning. Terms like “consultation” and “cooperation” exist along a continuum of intergovernmental engagement, which also includes “notification,” “coordination,” and “collaboration.” These five terms reflect increasing levels of integration between agencies and stakeholders. As illustrated in Figure 3, the framework, adapted from Sherry Arnsteinʼs “A Ladder of Citizen Participation” (1969) and modified by the U.S. DOT, presents a hierarchy of participation: Notification represents the most limited form of engagement (one-way communication), followed by consultation and cooperation, with coordination and collaboration at the highest levels of integration. Although originally developed to describe inter-MPO planning relationships, the framework is broadly applicable to state and non-metropolitan coordination. It helps clarify the evolving expectations for non-metropolitan involvement in statewide transportation planning, shifting from minimal awareness toward shared decision-making and joint plan development.

Long Description.

The figure presents a vertical framework labeled Integration, with an arrow indicating Low at the bottom and High at the top. Five levels are shown in ascending order. Notification, is an act of one way communication. The accompanying quote says My agency is doing this. Consultation, means that one or more parties confer with other identified parties in accordance with an established process and, prior to taking actions, considers the views of the other parties and periodically informs them about actions taken 23 CFR section 450.104. The accompanying quote says: Does your agency have any thoughts about how my agency should do this. Cooperation means that the parties involved in carrying out the transportation planning and programming processes work together to achieve a common goal or objective 23 CFR section 450.104. The accompanying quote says: Our agencies are sharing information and ideas. Coordination means the cooperative development of plans, programs, and schedules among agencies and entities with legal standing and adjustment of such plans, programs, and schedules to achieve general consistency, as appropriate 23 CFR section 450.104. The accompanying quote says: Our agencies are using the same data, tools, and processes. Collaboration is a joint process of creation. The accompanying quote says: Our agencies created this together. Source: Adapted from Multi-MPO Planning: A Transportation Practitionerʼs Guide. US DOT, 2020.

Another key element of MAP-21 was the formal recognition of federally designated RTPOs as entities eligible to carry out transportation planning in non-metropolitan areas. Although many states already had existing entities, such as Councils of Government (COGs), Regional Planning Commissions (RPCs), Regional Planning Affiliations (RPAs), or other regional planning bodies, that performed similar functions, MAP-21 marked the first time federal legislation provided a framework for the optional designation of RTPOs by states. This optional designation was significant because it provided greater legitimacy and visibility to rural planning efforts, encouraged more consistent engagement of rural stakeholders in statewide transportation processes, and offered a model for states lacking formal rural planning structures. While not accompanied by dedicated funding, the RTPO designation opened the door to eligibility for existing planning funds—such as State Planning and Research (SPR) funds under 23 USC—to support RTPO planning activities, making formal designation a viable, federally recognized planning pathway for states. The designation thus signaled a federal policy direction that emphasized the importance of rural involvement and laid the groundwork for stronger integration of non-metropolitan perspectives in long-range planning. Subsequent legislation, including IIJA, has built upon this foundation by expanding planning expectations and funding opportunities for states that formally designate RTPOs, reinforcing their role in shaping rural transportation priorities. Table 1 provides a comparative overview of the key legislative acts that govern how state DOTs coordinate with rural and non-metropolitan local officials. It highlights the evolving requirements and recommendations from 1991 to 2021, including funding allocation programs, consultation and cooperation practices, the option to federally designate agencies as RTPOs, and the shift towards a performance-based approach. Each act introduced changes or reinforced certain elements of the planning process, illustrating how the legislative framework has progressively shaped state transportation planning efforts in non-metropolitan areas.

Long Description.

The table has 8 rows and 6 columns. The column headers in Row 1 are Year, Act, Rural Eligible Funding Programs, Engagement with Non Metropolitan Officials, Creation of RTPOs, and Performance based approach. Row 2: 1991; ISTEA; dash; Consultation recommended; dash; dash. Row 3: 1998; TEA 21; check mark; Consultation recommended; dash; dash. Row 4: 2003; FHWA and FTA Rule; check mark; Consultation required; dash; dash. Row 5: 2005; SAFETEA-LU; check mark; Consultation required; Recommended; dash. Row 6: 2012; MAP 21; check mark; Cooperation required; Recommended; Recommended. Row 7: 2015; FAST; check mark; Cooperation required; Recommended; Required. Row 8: 2021; IIJA; check mark; Cooperation required; Recommended; Required. Source: Adapted from Regional Rural Transportation Planning and the Role of the Rural Planning Organizations Sriraj et al 2024 page 13.

Codes and Regulations

Each of these laws introduced new priorities, funding mechanisms, and planning requirements that shaped how state DOTs and rural transportation planning officials operate. However, while these acts establish broad policy goals and authorize funding levels, they do not, by themselves, dictate the specific legal and procedural requirements for transportation planning.

Instead, the details of how state DOTs must implement these legislative directives are codified in the USC and further clarified through the CFR. The USC provides the statutory framework that translates legislative intent into legally binding obligations, such as those found in Title 49 USC § 5304 and Title 23 USC § 135, which outline statewide and non-metropolitan planning requirements. Meanwhile, the CFR, particularly 23 CFR Part 450, establishes the regulatory procedures and standards that state DOTs must follow in their planning processes. As a result, state DOTs must navigate both the broad policy objectives of federal acts and the specific legal and regulatory mandates set forth in statute and regulation to develop compliant and effective transportation plans.

Statutory Requirements for Non-Metropolitan Planning

Title 49 USC § 5304 (public transportation) and Title 23 USC § 135 (highways) outline the federal requirements for statewide transportation planning, emphasizing a cooperative process that must involve non-metropolitan local officials. Specifically, states are required to “cooperate with affected local officials with responsibility for transportation” during the development of long-range statewide transportation plans and Statewide Transportation Improvement Programs (STIPs) [Title 49 USC § 5304(e)(1) and Title 23 USC § 135(e)(1)]. While the statute does not mandate cooperation with agencies, many states fulfill this requirement by working through RPEs, which serve as effective intermediaries for engaging non-metropolitan officials. In cases where RTPOs have been formally designated, states are also required to cooperate with them in accordance with the following federal criteria:

Note: See also 49 USC § 5304(f)(1) and (f)(2)(B)(i); and 49 USC § 5304(g)(1)(A) and (g)(2)(B)(i) for related statewide transportation planning criteria.

The USC also establishes specific processes for project selection in areas with populations of less than 50,000 individuals. For these rural areas, Title 49 USC § 5304(g)(6) and Title 23 USC § 135(g)(6) outline that states must select projects from the approved STIP in cooperation with non-metropolitan local officials who have transportation responsibilities. This cooperative approach ensures that local officials have a say in selecting projects that directly affect their communities. However, for some types of projects, such as those on the National Highway System or projects carried out under certain specific programs listed in the USC, the selection process is based on consultation rather than full cooperation.

Note: See also 49 USC § 5304(g)(6)(A) and (g)(6)(B) for related project selection criteria.

Establishment and Functions of RTPOs

Title 49 USC § 5304 and Title 23 USC § 135 also outline the provisions for the federal designation of RTPOs. According to these regulations, states have the option to establish RTPOs to “. . . enhance the planning, coordination, and implementation of statewide strategic long-range transportation plans and transportation improvement programs, with an emphasis on addressing the needs of nonmetropolitan areas of the State.” These regulations specify the structural requirements and duties necessary for the legal formation of an RTPO. However, if a state chooses not to establish or designate an RTPO, the regulations make it clear that the state still must cooperate with affected non-metropolitan local officials with transportation responsibilities.

RTPOs are made up of local rural officials and representatives from local transit systems. Each RTPO must have (1) a policy committee, where most members are local officials, but may also include state representatives, business leaders, transportation providers, and economic development experts, and (2) a fiscal and administrative agent, such as an existing regional planning and development organization, to handle planning, financial, and management responsibilities (commonly referred to as a “host” agency).

Title 49 USC § 5304(l)(4) and Title 23 USC § 135(m)(4) list the following duties for an RTPO:

The 3C Planning Process in Rural Contexts

Title 23 CFR Part 450 Subpart B elaborates on the process by which states must engage local officials in non-metropolitan areas, providing slightly more detailed procedural requirements for transportation planning. For example, it specifies the use of the “Continuing, Cooperative, and Comprehensive” (3C) process to ensure that planning efforts align with both federal and state transportation goals.

This 3C process was first introduced through the Federal-Aid Highway Act of 1962 to guide planning and programming in metropolitan areas. Over the years, it has been strengthened by legislative updates, particularly ISTEA, TEA-21, and MAP-21, which emphasized coordination and planning across broader regions. Today, the 3C process, as outlined in 23 CFR 450 Subpart B, extends to rural and non-metropolitan areas, ensuring a comprehensive and inclusive approach to statewide transportation planning [Sciara, 2017; 23 CFR § 450.210(a)].

Procedural Requirements for Cooperation

Title 23 CFR Part 450 Subpart B also prescribes some formal requirements for cooperation with non-metropolitan local officials representing units of general purpose local government and/or local officials with responsibility for transportation in creating long-term statewide transportation plans and the STIP. The regulation emphasizes the need for a documented cooperative process between state DOTs and non-metropolitan local officials that is separate from broader public involvement process. Further, it requires state DOTs to periodically review and solicit feedback on the effectiveness of their cooperative process with non-metropolitan officials [Title 23 CFR 450.210(b)].

State Variations in Coordination for Non-Metropolitan Transportation Planning

As described in the previous section, federal regulations establish the foundational requirements for coordination between state DOTs and non-metropolitan officials but leave significant discretion to the individual states to determine how to implement these processes. The regulations mandate that state DOTs must cooperate with local officials on transportation planning, document the cooperative process, and periodically review the processes with non-metropolitan stakeholders. However, the specific methods for achieving these requirements are left to states to define.

This aligns with the United Statesʼ federalist and decentralized system, which divides responsibilities among federal, state, and local governments, and offers significant flexibility in addressing complex challenges across the country. This decentralized structure enables states to respond to regional needs while still adhering to overarching federal guidelines, promoting localized decision-making that reflects the varying characteristics of each state (Conlan, 2017; Dilger, 2015).

Varied Structures and Functions of Regional Planning Entities (RPEs) Nationwide

Although federal RTPO designation shaped the conversation around rural planning in the early 2010s, the broader landscape of RPEs across the United States remains highly varied in structure and function. For the purposes of this report, the term “regional planning entity (RPE)” is used as an umbrella category to describe agencies that operate below the state level but above individual local governments, and that carry out at least some transportation planning responsibilities for non-metropolitan areas. These organizations vary widely in name, statutory authority, geographic scope, and area of focus.

Some RPEs primarily support transportation planning and are often designated in state statutes or commonly referred to as Rural Planning Organizations (RPOs), RPAs, or RTPOs, though their functions and responsibilities may vary by state. These entities often provide technical assistance, conduct long-range planning, assess needs, and recommend project priorities for non-metropolitan areas, functioning in many ways as MPO-like agencies for rural regions. Others are multipurpose regional entities with a broader mandate that integrates transportation with economic development, land use, housing, and environmental planning. These agencies, often designated in state statute or commonly known as COGs, RPCs, Planning District Commissions (PDCs), RDOs, or Planning and Development Districts (PDDs), may carry out a range of regional planning functions. Regardless of their structure, these broad RPEs often serve as critical intermediaries between local governments and state DOTs, performing essential functions such as regional transportation planning, corridor and safety studies, public engagement, and input into project prioritization for state funding and programming (Kissel, et al., 2016; Waldheim et al., 2014).

Because these organizations are complex, with overlapping roles and responsibilities, it is difficult to categorize them into strictly defined groups. However, Table 2 provides a useful way to

Long Description.

The table has 4 rows and 2 columns. The column headers in Row 1 are Function and Explanation. Row 2: Broad Regional Planning and Development Agencies; Entities that integrate transportation with economic development, housing, and other planning disciplines. Examples include Councils of Government COGs, Regional Planning Commissions RPCs, Planning District Commissions PDCs, Regional Development Organizations RDOs, Planning and Development Districts PDDs. Row 3: Transportation Focused Regional or Rural Planning Organizations; Groups whose main purpose is rural transportation planning, providing technical assistance, long range planning, and project prioritization for non MPO areas. Examples include Rural Planning Organizations RPOs, Regional Transportation Planning Organizations RTPOs, Transportation Planning Regions TPRs, Regional Transportation Planning Agencies RTPAs, Regional Planning Affiliations RPAs. Row 4: Advisory and Coordination Bodies; Entities that serve as forums for collaboration between local governments, state DOTs, and other stakeholders without direct project implementation authority. Examples include Area Commissions on Transportation ACTs.

visualize some of the key differences in their primary focus areas while acknowledging that many organizations serve multiple purposes and may not fit neatly into a single category.

Prior to MAP-21ʼs enactment, approximately half of U.S. states had already established some form of RPE to support rural transportation planning (Kissel et al., 2016). These entities, such as Ohioʼs multi-county RDOs and Washingtonʼs RTPOs, were created through state legislation or administrative action prior to 2012 to provide a regional forum for coordination, long-range planning, and project development [Washington State Department of Transportation (WSDOT), 2019; Ohio Department of Transportation (ODOT), 2022]. While MAP-21 introduced a federal framework for recognizing RTPOs, states varied widely in their responses. Some integrated elements of the federal guidance into their existing structures, while others chose to continue operating under state-specific models that already supported non-metropolitan planning efforts. In many cases, the functional roles of RPEs, regardless of title or designation, closely aligned with or exceeded the expectations set out in federal guidance (Kissel et al., 2016). Still, a handful of states with sparse populations and large rural areas, such as Wyoming and Nevada, opted not to establish regional entities, instead managing non-metropolitan transportation planning directly through their state DOTs in coordination with rural officials with transportation responsibilities [Nevada Department of Transportation (NDOT), 2024; Wyoming Department of Transportation (WYDOT), 2010].

State Guidance on Non-Metropolitan Planning Coordination

State DOTs vary widely in the extent and formality of their guidance for coordinating with non-metropolitan transportation planning partners. Some states have issued detailed manuals or procedural documents, while others rely on informal communication and long-standing practices. Several states, including Arizona, Ohio, Nevada, California, North Carolina, and Washington, have developed written resources that outline roles, planning requirements, and coordination processes for RPEs. The Ohio RTPO Administration Manual (ODOT, 2022), Nevada Department of Transportation Rural Engagement Plan (NDOT, 2024), and the California Department of Transportation (Caltrans) Regional Planning Handbook (Caltrans, 2017) are used as representative examples in this literature review to illustrate the different approaches states have taken to structure and support coordination with rural and non-metropolitan planning entities.

Ohio Department of Transportation (ODOT)

The Ohio RTPO Administration Manual outlines the administrative processes, planning expectations, and coordination procedures between ODOT and the stateʼs eight RTPOs. Developed by ODOTʼs Office of Statewide Planning and Research, the manual provides a standardized framework for RTPOs operating in non-metropolitan areas to engage in regional transportation planning activities and to support alignment with statewide goals.

Prior to the enactment of MAP-21, Ohio already had RPEs in place that supported non-metropolitan transportation planning in coordination with ODOT. In 2013, ODOT launched a pilot program to help several existing RPEs meet the federal requirements for RTPO designation under 23 USC § 135. By the end of the 2-year pilot, five agencies [Buckeye Hills Regional Council, Logan-Union-Champaign (LUC) Regional Planning Commission, Maumee Valley Planning Organization (MVPO), Ohio Mid-Eastern Governments Association (OMEGA), and the Ohio Valley Regional Development Commission (OVRDC)] had developed long-range transportation plans (LRTPs), established consultation processes with rural stakeholders, and demonstrated planning capacity. These agencies were formally designated as RTPOs by the Governor of Ohio in 2016 (ODOT, 2022). Since then, additional designations have occurred: The Central Ohio Rural Planning Organization (CORPO) was designated in 2019; the West Central Ohio Rural Planning

Organization (WORPO) was established in 2023; and the Miami Valley Regional Planning Commission (MVRPC) was designated as the RTPO for the Darke-Preble-Shelby (DPS) Region in 2024 (ODOT, 2025a; ODOT, 2025b).

Responsibilities

The Ohio RTPO Administration Manual details a planning structure for RTPOs that includes several elements commonly associated with metropolitan planning. For instance, each RTPO has three required transportation documents: an LRTP updated every 5 years, a Regional Transportation Improvement Program (RTIP) updated every 2 years, and an RTPO Work Program updated annually. The manual specifies that LRTPs should include regional goals and objectives, analyses of existing and future transportation needs, evaluation of strategies, and documentation of stakeholder input.

Funding

Funding for Ohioʼs RTPOs is primarily provided through ODOTʼs SPR program, which allocates federal funds requiring a 20% local match. ODOT typically contributes 10% of this match using state funds, while the remaining 10% must be provided by the RTPO through local sources. However, if ODOT chooses not to contribute its portion, the RTPO becomes responsible for the full 20% match. The use of SPR funds must be detailed in the RTPO Work Program budget tables.

To distribute SPR funds among RTPOs, ODOT developed an allocation formula that includes a base amount of funding for each agency, with the remaining funds distributed based on a 50/50 weighting of population and land area. When the RTPO Program was initially established, the original five RTPOs shared an annual budget of $770,000. Each received a base allocation of $60,500 (totaling $302,500), and the remaining $467,500 was distributed proportionally by population and area. These per capita and per square mile rates continue to be used to calculate funding for RTPOs designated after the original five. While the example reflects the initial funding structure, ODOT has since increased the base allocation, and the total program budget is reviewed annually to ensure it aligns with evolving statewide planning needs.

Governance and Organizational Structure

ODOT plays a central role in administering Ohioʼs RTPO Program through both its Central Office and District Offices. ODOTʼs Central Office is responsible for fiscal oversight, ensuring compliance with federal funding requirements through review of annual RTPO Work Programs and associated invoices. It also provides technical assistance, including training and data support, and assigns a liaison to each RTPO to communicate ODOT programs and policies. At the district level, ODOT staff are expected to actively participate in the RTPO planning process to offer the stateʼs perspective and help shape regional transportation priorities. District liaisons serve as key points of contact, sharing information about ODOT projects and coordinating with RTPOs on the District Capital Program (ODOT, 2022).

Structurally, each RTPO must establish a policy committee that serves as the official decision-making body. This committee must be composed primarily of non-metropolitan local officials, but it may also include representatives from the state, private sector, transit providers, economic development, and the public. According to the manual, ODOT contracts with host agencies “. . . willing to house a staff responsible for assisting the [policy committees] in performing the policy development, technical analysis, and administrative activities necessary for conducting the areaʼs planning process” (ODOT, 2022). Importantly, these host agencies do not constitute the RTPOs; the policy committee itself is the formally designated RTPO. RTPOs may also choose to establish Technical Advisory Committees to offer guidance on technical matters, transportation methodologies, and project implementation. Additional committees, such as Citizenʼs Involvement Committees or modal-specific subcommittees, may also be created to enhance participation

and focus on key transportation issues like accessibility. See Figure 4 for a diagram of the Ohio RTPO organizational structure.

Section 1.5 of the Ohio RTPO Administration Manual emphasizes the importance of interagency agreements in clearly defining roles and responsibilities within the RTPO planning process, while also serving as critical documentation for auditing and legal purposes. Some agreements described in the manual are mandated, while others are recommended in the manual as best practices. The required agreements include:

• State and RTPO Handling Agency Agreements: These are executed biennially between each RTPO fiscal/administrative agent (the host agency) and the State of Ohio. The agreement details cooperative planning efforts between ODOT and the RTPO for non-metropolitan areas.

Long Description.

RTPO Policy Committee: The entity formally designated as the Regional Transportation Planning Organization and is responsible for conducting the areaʼs transportation planning process. Members include: Nonmetropolitan Local Officials. ODOT District Deputy Director. Additional representatives from the State, private business, transportation service providers, economic development practitioners, and the public in the region. Three arrows lead to the RTPO Policy Committee, one each from the Technical Advisory Committee TAC, Other Committees, and the RTPO Handling Agency. Technical Advisory Committee TAC: Each RTPO has the option to appoint a TAC with the primary role of providing advice to the RTPO board or policy committee in regard to professional and technical considerations involved in plans and decisions. Members include: Local transportation planners and engineers. ODOT District Planning staff. Local public transit operators. Other transportation and environmental related agencies. Other Committees: The RTPO may establish other committees as deemed necessary and appropriate. Examples include a Citizenʼs Involvement Committee or sub committees dedicated to a specific transportation mode bicycling, transit, et cetera or related issues such as accessibility, senior citizens, environmental justice, funding, et cetera. Two arrows point from the RTPO Handling Agency, one toward the TAC and one toward the Other Committees. RTPO Handling Agency: The government entity that houses the professional RTPO staff who assist the board in performing the policy development, technical analysis, and administrative activities necessary for conducting the areaʼs planning process. Contractual agreements are between the fiscal and administrative agent and ODOT: Professional RTPO Staff, Technical Director. The RTPO Handling Agency leads to Technical Advisory Committee, Other Committees, and RTPO Policy Committee. TAC and Other Committees also lead to RTPO Policy Committee. Source: Ohio RTPO Administration Manual, ODOT, 2022, page 10.

• RTPO/RTPO and RTPO/MPO Agreements: These are required when planning boundaries overlap between RTPOs or between an RTPO and an MPO. The agreement defines shared responsibilities to support coordinated, cooperative, and continuous planning in border areas.

The two recommended agreements listed in the manual are as follows:

• RTPO and Local Jurisdiction Agreements: RTPOs are encouraged to establish standing cooperation agreements with all counties and incorporated municipalities in the planning area.
• RTPO and Transit Operator Agreements: RTPOs should enter into Memorandums of Understanding (MOUs) with public transit operators in the region. These MOUs clarify cooperative roles and responsibilities in transportation planning.

Nevada Department of Transportation (NDOT)

Nevada approaches rural transportation planning through a centralized model in which the NDOT headquarters staff directly coordinates with local officials, rather than working through RPEs. This approach is formalized in NDOTʼs 2024 Rural Engagement Plan (REP), which outlines the departmentʼs strategies for engaging with rural communities across the state. NDOT manages engagement directly through structured outreach efforts, including regular meetings, workshops, and ongoing communication channels. The REP describes these outreach efforts as an iterative process with the following four key elements also shown in Figure 5 (NDOT, 2024):

• Workshops: NDOT hosts workshops in each county, inviting local and tribal leaders and staff to discuss regional transportation needs. NDOT presents information about upcoming funding

Long Description.

The circular process diagram is titled, Public stakeholder input, NDOT advisory committees, planning and technical studies. It includes four steps. Step 1: Local Agency Workshops: Coordination meetings with local agencies, Discuss agency requests, Review One Nevada analysis, Step 2: NDOT Analysis: Advance the One Nevada process, Develop upcoming year work program, Coordinate with districts, Coordinate with local agencies. Step 3: NDOT County Leadership Meetings: Present NDOT work program, which reflects previous coordination, Seek additional input. Step 4: NDOT Analysis: Review local agency requests, Perform One Nevada needs analysis, Coordinate with districts, Coordinate with local agencies. Step 4 points back toward Step 1 and a repetition of the process. Source: NDOT, 2024, page 17.

opportunities and areas for further collaboration between NDOT and local agency staff. A key element of the workshop is communication about local transportation concerns and requests, with a focus on NDOT facilities.

• NDOT Technical Analysis and Coordination (Round One): After the workshops, NDOT integrates local input into its statewide planning process, including needs assessments and project development. District offices and the Rural Liaison continue working with local agencies on planning and support.
• NDOT/County Leadership Meetings: NDOTʼs Director and leadership meet with county officials every other year to review the STIP and annual work program. These meetings support high-level dialogue and allow counties to share priorities and feedback.
• NDOT Technical Analysis and Coordination (Round Two): NDOT maintains regular coordination with rural partners during plan updates, project development, and related studies. The Rural Liaison and district staff remain available for support and ongoing collaboration.

As noted in the workshop component of NDOTʼs REP, tribal leaders are invited to participate in planning discussions. It is important to acknowledge that tribal governments, while often located in non-metropolitan areas, engage with state DOTs through separate federal consultation requirements due to their status as sovereign nations. A comprehensive review of tribal-state coordination practices falls outside the scope of this synthesis; however, their participation is recognized as an important facet of rural transportation planning in many states.

The plan also highlights NDOTʼs intent to support data-informed decision-making. NDOT gathers and evaluates information on roadway conditions, traffic volumes, safety concerns, and community needs, using these data to guide planning priorities and identify funding opportunities. The REP describes a commitment to performance monitoring, including the use of defined metrics to assess outcomes and inform future investments.

Nevadaʼs rural engagement process is supported by a range of ongoing coordination efforts designed to ensure continuous input from local stakeholders. NDOT maintains a County Dashboard, an online tool that provides transportation activity updates for each county and allows local officials to submit questions or requests. Regular stakeholder input is also gathered through several advisory committees: The Transportation Planning Advisory Committee and Freight Advisory Committee meet quarterly and include representatives from local governments and industry; the Bicycle and Pedestrian Advisory Committee focuses on non-motorized infrastructure; and the Nevada Advisory Committee on Traffic Safety supports safety planning through multidisciplinary collaboration. NDOT also disseminates information and invites public engagement through its website. Beyond formal committees, NDOT staff attend various meetings hosted by partner organizations such as the Nevada Association of Counties, the Nevada League of Cities, the Nevada Chapter of the American Planning Association (APA), and regional economic development agencies to stay informed about rural issues and priorities.

California Department of Transportation (Caltrans)

In California, every county is served by a Regional Transportation Planning Agency (RTPA), a type of RPE established under state law to lead transportation planning. These agencies go by various names depending on the region, including local transportation commissions, county transportation commissions, COGs, and associations of governments. While their titles may differ, they share the same core responsibilities and statutory foundation under California Government Code § 29532 et seq. (Caltrans, 2024).

In counties that include urbanized areas with populations over 50,000, an MPO is also designated to conduct federally required transportation planning. In California, many MPOs are also

known locally as councils or associations of governments, and most function as both the MPO and the RTPA for their respective regions. The main structural difference lies in the governance and coverage areas. For instance, MPOs may serve a single or multiple counties, while RTPAs only serve a single county. In most regions, the boundaries of MPOs and RTPAs align, but there are exceptions. For example, in the case of the Association of Monterey Bay Area Governments (AMBAG), the MPO does not serve as the RTPA. Instead, the three counties within AMBAG, Santa Cruz, Monterey, and San Benito, each have their own county-level RTPA (Caltrans, 2017). Depicted in Figure 6 are the 44 total RTPAs in California: 18 are compound MPOs (shown in green) and 26 are designated as non-MPO RTPAs (shown in grey if the RTPA is not covered by an MPO and green with black dots if it is a stand-alone RTPA with its own non-metropolitan planning responsibilities but falls within the boundary of an MPO).

Responsibilities

RTPAs are responsible for preparing three core planning documents: an LRTP (called a “Regional Transportation Plan (RTP)” in California) updated every 5 years, an RTIP updated every 2 years, and the annually updated Overall Work Program (OWP) (Caltrans, 2017).

Funding

Non-MPO RTPAs in California are primarily funded through a mix of state and federal transportation planning programs administered by Caltransʼs Office of Regional Planning (ORP) (Caltrans, 2017). The cornerstone of their funding is the Rural Planning Assistance Program, a state-funded program allocated by formula based on population, as authorized under California Public Utilities Code § 99311.1. For FY 2024–25, total Rural Planning Assistance funding was $6.5 million, with each of the 26 non-MPO RTPAs receiving between $125,000 and $422,000. These funds are distributed on a reimbursement basis with no local match requirements (Caltrans, n.d.). In addition to Rural Planning Assistance funds, non-MPO RTPAs may receive federal planning support through the Consolidated Planning Grant (CPG) program and can compete for discretionary funds from the Sustainable Transportation Planning Grant Program, which includes Sustainable Communities and Strategic Partnerships grants. Some RTPAs also leverage additional funding sources, including local sales tax returns, Planning, Programming, and Monitoring (PPM) funds, FTA Section 5305 grants, and regional mitigation fees (Kissel, et al., 2016; Caltrans, 2017).

Governance and Organizational Structure

The governance and organizational structure of non-metropolitan RTPAs in California reflects the decentralized and adaptive nature of regional planning in the state. While all RTPAs are governed by policy boards made up of local elected officials, typically city councilmembers and county supervisors, the structure beyond that varies based on how the agency was formed and the scope of its responsibilities.

Non-MPO RTPAs are either created by state statute or established as the result of cities and counties forming a joint powers authority (JPA) under California Government Code § 6500 (Cypher and Grinnell, 2007; Higgins, 2020). Statutory RTPAs operate within narrowly defined authorities outlined in their enabling legislation, including the composition of their boards and allowable activities. In contrast, RTPAs formed as JPAs, often called COGs, are more flexible. These agencies are the result of voluntary agreements among cities and counties to work together on shared priorities and can broaden or limit their scope of authority based on the terms of the JPA agreement (Cypher and Grinnell, 2007; Higgins, 2020).

Structurally, RTPAs range from small, lean agencies hosted within a county public works or planning department, to independent organizations with dedicated staff and office space.

Many smaller or rural RTPAs, such as the Alpine County Local Transportation Commission, are hosted within a county government, meaning the county provides administrative support (e.g., HR, payroll, and IT), while planning staff work directly on RTPA responsibilities (Alpine County, n.d.). Others, such as the Shasta Regional Transportation Agency, operate independently with their own executive director and staff (Shasta Regional Transportation Agency, 2017).

Some RTPAs also maintain advisory committees, such as Technical Advisory Committees made up of local public works directors, planners, or transit agency staff, to provide input on project selection, policy issues, or the development of the RTP. Special advisory committees, including bicycle and pedestrian groups or social services transportation advisory councils (SSTACs), may also be convened to meet state planning requirements, particularly in relation to the coordination of services for seniors and people with disabilities; however, the number and activity of such committees often depend on the agencyʼs resources and planning needs (Caltrans, 2017).

Summary of Literature Review Findings

Federal Legislative and Regulatory Context

• Federal surface transportation legislation (e.g., ISTEA, TEA-21, SAFETEA-LU, MAP-21, and IIJA) requires states to engage in a 3C transportation planning process, including coordination with rural and non-metropolitan areas.
• While MPOs are the federally designated planning agencies for metropolitan areas, no direct federal equivalent exists for rural areas; instead, states must provide for consultation with non-metropolitan local officials during statewide planning.
• Title 23 CFR § 450.210 outlines the requirement for documented processes for non-metropolitan consultation, and subsequent legislation has continued to reinforce the importance of rural involvement.
• The literature refers to non-metropolitan planning entities by various names, including RPOs, RPAs, RTPOs, and other regional entities. Throughout this report, RPE is used as a general term to describe any substate, multi-jurisdictional organization involved in transportation planning outside of MPAs.
• RTPOs are a type of RPE that supports transportation planning in non-metropolitan or rural areas in coordination with the state DOT. While RTPOs were already operating in several states prior to 2012, the term RTPO was formally adopted by the federal government in MAP-21 as the federal designation for these types of organizations. However, states vary in their use of terminology and governance structures. Some states have agencies called RTPOs that are not federally designated under MAP-21, while others perform RTPO-like functions under different names such as RPOs, PDDs, or COGs. As such, RTPO has become a federal umbrella term, but the naming conventions and functions of rural planning agencies remain varied across states.

State Practices and Guidance

• Several state DOTs have adopted formal guidance, policies, or manuals that describe coordination protocols with non-metropolitan planning agencies.
• For example, states like Ohio, Nevada, California, North Carolina, and Washington have developed clearly defined roles, responsibilities, and expectations for their RPO or RTPO partners.
• Some states provide funding and technical support to these entities to enable rural transportation planning, often linking this support to specific deliverables or performance measures.

Coordination Mechanisms

• Coordination mechanisms between state DOTs and non-metropolitan planning agencies can be formal or informal.
  • Formal mechanisms include MOUs, intergovernmental agreements, state-level manuals, and annual work programs.
  • Informal mechanisms include regular phone calls, staff check-ins, attendance at regional meetings, and ad-hoc technical support.
• States with strong coordination practices often maintain dedicated liaison staff or rural planning coordinators within the state DOT.
• Participation in statewide planning processes is frequently facilitated through advisory committees or rural technical advisory groups.
• Cooperation models vary widely across states, ranging from centralized approaches, where state DOT headquarters directly engage with local officials, to decentralized systems that rely on district offices or regional entities to manage planning activities; hybrid models combine elements of both, balancing statewide guidance with regional autonomy.