On March 11, 2025, the U.S. Department of Transportation (DOT) issued a memo to state transportation agencies calling for a review of all competitive grant programs and awards. In some instances, this can include a project-by-project review.
The memo applies to competitive grant selections made after January 20, 2021 (FY 2022 – FY 2025) that have not yet completed grant agreements or obligated the funding, including those that have only been partially obligated. Projects with existing and executed grant agreements are not subject to additional review, but any new federal dollars made out to those projects would be.
According to the memo, the focus of this review is to identify project scope and activities that are allocating funding to advance climate, equity, and other priorities counter to the Administration’s Executive Orders.
Modal agencies are instructed under the directive to identify programs that may include elements of “equity activities, Diversity, Equity, and Inclusion (DEI) activities, climate change activities, environmental justice (EJ) activities, gender-specific activities, when the primary purpose is bicycle infrastructure (i.e., recreational trails and shared-use paths, etc.), electric vehicles (EV), and EV charging infrastructure.”
Programs that meet certain criteria, will be subject to a project-by-project review.
Project-by-project reviews will examine and flag any project scope elements or activities for potential removal, including:
- Project activities such as equity analysis, green infrastructure, bicycle infrastructure, EV and/or EV charging infrastructure.
- Project purpose or primary project benefits include equity and/or climate such as projects that purposefully improve the condition for EJ communities or actively reduce GHG emissions.
Based on their review, agencies must recommend to the Office of the Secretary which project selections should continue in their current form with no change, be revised with a reduced or modified scope, or be canceled entirely.
For those projects requiring revision, the agency will negotiate with the project sponsor to update the project scope to eliminate and replace identified project elements that align with the program statute, scope of the project sponsor’s application, and Trump Administration Executive Orders.
If the project sponsor does not agree to remove project elements and replace with acceptable alternative scope, then the Team should proceed, the memo directs that the agency should proceed with a reduced award that removes the flagged scope and activities.