BCG Develops Part 659 Implementation Toolkit

Background
49 CFR Part 659 establishes FTA’s State Safety Oversight (SSO) Program, mandates the development state agencies, and outlines the requirements for state program standards to oversee the safety and security of local rail transit systems.  The original requirements for FTA’s State Safety Oversight (SSO) Program went into effect on January 1, 1997.  On March 9, 2004, FTA initiated its Notice of Proposed Rulemaking (NPRM) process to revising the SSO rule.

Approach
Prior to the initiation of the NPRM process, we solicited feedback from all SSO agencies and rail transit agencies by asking them to revise the existing Part 659 implementation guidelines.  We encouraged SSO agencies to make changes that they would like reflected in a revised Part 659.  We managed all changes in a master document and facilitated a series of teleconferences to discuss proposed changes and gain revision consensus.  Based on all SSO input, we developed language for the revised Part 659 for FTA’s NPRM process.  Throughout the NPRM process, we managed all formal comments, and developed all response language, as well and any final Part 659 revisions prior to finalization.  To provide SSO community members with useful tools for implementing the revised rule, we developed a series of reference materials and SSO documentation templates to facilitate the state and transit agency documentation development process.

Results
FTA’s revised Part 659 was published on April 29, 2005.  BCG’s support and revision process ensured that the final rule incorporated the concerns and addressed the needs of the SSO Community.  Additionally, BCG provided SSO agencies and rail transit agencies with a revised Implementation Guidelines document to assist agencies to comply with the new rule, as well as a Resource Toolkit containing SSO documentation samples to help agencies to develop compliant program documents.