Op. Atty. Gen. 229a(Cr. Ref. 1005, 1007, 1016)

\ DEPARTMENT OF TRANSPORTATION: RESPONSIBILITIES: CONSTRUCTION: Responsibilities of Commissioner of Transportation and Metropolitan Council in connection· with construction of light rail transit project discussed: Minn. Stat. §§ 471.59, 473.399 473.3997. 229A (Cr. ref. 1005, 1007, 1016) June 30, 2000 Representative Jim Rhodes, Chairman Governmental Operations and Veterans Affairs Policy Committee Minnesota House of Representatives 409 State Office Building, 100 Constitution Avenue St. Paul, MN 55155-1206 Dear Chairman Rhodes: Thank you for your letter in which you requested a formal opinion, pursuant to Minn. Stat. § 8.05, regarding the Hiawatha Light Rail P-roject Management Plan. Your letter was accompanied by a resolution, passed May 1, 2000, of the House Governmental Operations and Veterans Affairs Policy Committee. Your letter and the resolution requested that--t;p.is Office opine as to whether the Hiawatha Light Rail Project Management Plan, as submitted by the Metropolitan Council and approved by the Federal Transit Administration, conforms with Minnesota Statutes and the Legislature's intent for control of the project. FACTS- I. OVERVIEW OF PROJECT MANAGEMENT PLAN. A project management plan is a detru.Ted document required by the Federal Transit Administration ("FTA") to be submitted by parties seeking grants from the FTA. The Hiawatha Light Rail Project Management Plan ("PMP") was submitted to the FTA by the Metropolitan Council, as the proposed grantee of the FTA funds. The Attorney General's Office has obtained a copy of the PMP 1 dated April 14, 2000, a copy of which is attached as Exhibit 1. Chapter 2 of the PMP is entitled "Management Organization, Approach and Responsibilities." The Metropolitan Council has advised this Office that the PMP dated April 14, 2000 was submitted to the FTA and subsequently approved by it. 1 The Attorney General's Office has received and reviewed only Chapter 2 of the PMP. Unless the context indicates otherwise, references herein to the PMP refer to Chapter 2 of the PMP. Representative Jim Rhodes June 30, 2000 Page 2 The PMP sets forth a detailed description of "the scope of the [light rail transit] project implementation during preliminary engineering, final design, construction startup, and revenue services." PMP <][2.01. The PMP states that its focus is on "a description of adequate staff organization, complete with well-defined reporting relationships, statements and functional responsibilities, job descriptions and job qualifications and... [a] description of organizational structures, management skills, and staffing levels required throughout the construction phase" of the light rail transit project. PMP '][2.01. In outlining responsibilities for the project, the PMP states as follows: The project blends the strengths of the Metropolitan Council, the Minnesota Department of Transportation, the Metropolitan Airports Commission, and other project partners. The Metropolitan Council is the Federal grantee, and is in charge of the project. Mn/DOT is responsible for designing af!d constructing the project, and the Metropolitan Airports Commission is responsible for construction of the tunnel and airport station. PMP '1[2.04. l. The following describes the respective responsibilities and a:ttthority of the Metropolitan Council and the Department of Transportation as described in the PMP. II. RESPONSIBILITIES OF DEPARTMENT OF TRANSPORTATION The PMP states that "as delineated in the state's enabling legislation (Mitrn. Stat. §§ 473.399-473.3998), the Minnesota Department of Transportation, acting through its Commissioner, has primary responsibility for the design and construction of the project." PMP '1[2.04.4.2. However, the PMP also states that the Department of Transportation's role in the project is to serve as an "agent" of the Met Council. PMP