Defining "small Starts"

[pineda]

as defined by the EPA

section 5309 has been amended to add a new subsection (3)

containing a new capital investment program category for projects

requesting federal funding of less than $75,000,000 with a total

project cost of less than $250,000,000. That new capital investment

program, which will be referred to as the ``Small Starts'' program,

While we believe that the New Starts process represents a good

starting point for the development of the new Small Starts program, it

is clear from the statutory and report language that significant

simplification is contemplated.

First,

the expanded definition of eligibility raises a number of questions.

Second, tailoring the project rating and evaluation process to the

smaller scale and different nature of the projects, which are likely to

be proposed for funding in this program deserves further attention.

Finally, the project development process should also be scaled to

properly reflect the size and nature of these projects.