US 50/301(Chesapeake Bay Bridge)

[Beltway]

A TIFIA loan is still a federal credit instrument, and it cannot be issued until USDOT signs off on the project's financial plan, revenue assumptions, risk profile, and ability to repay. That review is every bit as rigorous as FHWA's approval for grant dollars, and it happens after NEPA but before any construction NTP.

If anything, TIFIA makes the fiscal hurdle higher, because the feds have to be convinced the toll revenue can actually support $14–15B in debt service.

[Rothman]

A TIFIA loan is still a federal credit instrument, and it cannot be issued until USDOT signs off on the project's financial plan, revenue assumptions, risk profile, and ability to repay. That review is every bit as rigorous as FHWA's approval for grant dollars, and it happens after NEPA but before any construction NTP.

If anything, TIFIA makes the fiscal hurdle higher, because the feds have to be convinced the toll revenue can actually support $14–15B in debt service.

Eh, worked for the Tappan Zee Bridge.

[Beltway]

A TIFIA loan is still a federal credit instrument, and it cannot be issued until USDOT signs off on the project's financial plan, revenue assumptions, risk profile, and ability to repay. That review is every bit as rigorous as FHWA's approval for grant dollars, and it happens after NEPA but before any construction NTP.
If anything, TIFIA makes the fiscal hurdle higher, because the feds have to be convinced the toll revenue can actually support $14–15B in debt service.

Eh, worked for the Tappan Zee Bridge.

$3.5 billion on a very well funded Thruway.

MDTA does run seven toll facilities, but their combined revenue base is still a fraction of the Thruway's. NYSTA supports a 570‑mile system, multiple high‑volume cash cows, and the implicit backing of the State of New York. MDTA would be trying to support a $14-15 billion package on a much smaller system, with the entire debt load effectively tied to one bridge. The credit math is completely different. "Seven facilities" doesn't make the revenue base comparable or the risk profile similar.

[Rothman]

A TIFIA loan is still a federal credit instrument, and it cannot be issued until USDOT signs off on the project's financial plan, revenue assumptions, risk profile, and ability to repay. That review is every bit as rigorous as FHWA's approval for grant dollars, and it happens after NEPA but before any construction NTP.
If anything, TIFIA makes the fiscal hurdle higher, because the feds have to be convinced the toll revenue can actually support $14–15B in debt service.

Eh, worked for the Tappan Zee Bridge.

$3.5 billion on a very well funded Thruway.

MDTA does run seven toll facilities, but their combined revenue base is still a fraction of the Thruway's. NYSTA supports a 570‑mile system, multiple high‑volume cash cows, and the implicit backing of the State of New York. MDTA would be trying to support a $14-15 billion package on a much smaller system, with the entire debt load effectively tied to one bridge. The credit math is completely different. "Seven facilities" doesn't make the revenue base comparable or the risk profile similar.

I'm becoming not sure of what your point is.  Is it just "This is never going to happen because I don't see the funding becoming available," whereas I'm saying, "Eh, it seems they're going to figure it out"?  If that's the case, we're just two sides of the same coin.

[vdeane]

The idea that a transportation agency would go through the preliminary design process (including NEPA) without having a plan to fund the project is just wild to me.  To the extent that I've been involved with projects that have gotten that far only to be delayed or cancelled, the cause was either the unprecedented cost inflation following COVID or something unrelated to funding (for instance, a rail company retaking a line another company had been operating on).

[Beltway]

I'm becoming not sure of what your point is.  Is it just "This is never going to happen because I don't see the funding becoming available," whereas I'm saying, "Eh, it seems they're going to figure it out"?  If that's the case, we're just two sides of the same coin.

I'm not saying "never," and I'm not arguing that MDTA is incapable of solving problems. I'm saying the financing structure they're pointing to doesn't scale to a $15 billion single‑asset package the way it did for the Thruway.

The Thruway could support a $3.5 billion new TZB because it has a massive, diversified revenue base and the implicit backing of a state with deep pockets. MDTA's system is much smaller, its margins are thinner, and this project would concentrate essentially the entire debt load on one facility. That's not a philosophical point -- it's a credit‑risk issue.

If the funding materializes, great. But the hurdle isn't NEPA or willpower; it's whether USDOT and the credit markets believe MDTA's revenue can actually carry $14-15 billion in debt service when the currently legislated limit is $4 billion. That's the bottleneck. Optimism doesn't change the math.

[Rothman]

I'm becoming not sure of what your point is.  Is it just "This is never going to happen because I don't see the funding becoming available," whereas I'm saying, "Eh, it seems they're going to figure it out"?  If that's the case, we're just two sides of the same coin.

I'm not saying "never," and I'm not arguing that MDTA is incapable of solving problems. I'm saying the financing structure they're pointing to doesn't scale to a $15 billion single‑asset package the way it did for the Thruway.

The Thruway could support a $3.5 billion new TZB because it has a massive, diversified revenue base and the implicit backing of a state with deep pockets. MDTA's system is much smaller, its margins are thinner, and this project would concentrate essentially the entire debt load on one facility. That's not a philosophical point -- it's a credit‑risk issue.

If the funding materializes, great. But the hurdle isn't NEPA or willpower; it's whether USDOT and the credit markets believe MDTA's revenue can actually carry $14-15 billion in debt service when the currently legislated limit is $4 billion. That's the bottleneck. Optimism doesn't change the math.

Well, there we are, then:  Just both waiting to see what happens in less than a year.

[Beltway]

The idea that a transportation agency would go through the preliminary design process (including NEPA) without having a plan to fund the project is just wild to me.  To the extent that I've been involved with projects that have gotten that far only to be delayed or cancelled, the cause was either the unprecedented cost inflation following COVID or something unrelated to funding (for instance, a rail company retaking a line another company had been operating on).

What you're describing is absolutely true for state‑funded projects or anything in the $50–500 million range. But once you get into multi‑billion‑dollar federally reviewed megaprojects, the sequencing flips: NEPA routinely precedes any firm funding plan.

FHWA doesn't require a financial package to publish a DEIS, FEIS, or even to issue a ROD. NEPA is an environmental clearance, not a fiscal commitment. Agencies advance it precisely because it's the cheapest part of the process -- a few tens of millions in studies versus billions in capital. It keeps options alive while the funding picture evolves, which can take years.

There's a long list of FEIS/ROD projects that stalled because the money never materialized: the Brent Spence companion bridge (pre‑IIJA), the I‑94 East‑West in Milwaukee, the Garden Parkway in NC, the Portsmouth bypass in OH, multiple Texas urban freeway rebuilds, etc. All had NEPA done. None had funding locked in.

So it's not "wild" -- it's standard practice on megaprojects. NEPA moves forward because it can move forward. The fiscal gate comes later, and that's exactly where MDTA's $15 billion problem sits.

And if you want a long‑term example, the Third Hampton Roads Crossing (CBA 9) fully completed NEPA in 2000 and then sat untouched for over twenty years because the region couldn't fund it -- a textbook case of how a signed ROD doesn't guarantee construction.  Technically is is still untouched -- HRBT Expansion is an alternative that was unselected in that study. 

[Rothman]

The idea that a transportation agency would go through the preliminary design process (including NEPA) without having a plan to fund the project is just wild to me.  To the extent that I've been involved with projects that have gotten that far only to be delayed or cancelled, the cause was either the unprecedented cost inflation following COVID or something unrelated to funding (for instance, a rail company retaking a line another company had been operating on).

What you're describing is absolutely true for state‑funded projects or anything in the $50–500 million range. But once you get into multi‑billion‑dollar federally reviewed megaprojects, the sequencing flips: NEPA routinely precedes any firm funding plan.

FHWA doesn't require a financial package to publish a DEIS, FEIS, or even to issue a ROD. NEPA is an environmental clearance, not a fiscal commitment. Agencies advance it precisely because it's the cheapest part of the process -- a few tens of millions in studies versus billions in capital. It keeps options alive while the funding picture evolves, which can take years.

There's a long list of FEIS/ROD projects that stalled because the money never materialized: the Brent Spence companion bridge (pre‑IIJA), the I‑94 East‑West in Milwaukee, the Garden Parkway in NC, the Portsmouth bypass in OH, multiple Texas urban freeway rebuilds, etc. All had NEPA done. None had funding locked in.

So it's not "wild" -- it's standard practice on megaprojects. NEPA moves forward because it can move forward. The fiscal gate comes later, and that's exactly where MDTA's $15 billion problem sits.

And if you want a long‑term example, the Third Hampton Roads Crossing (CBA 9) fully completed NEPA in 2000 and then sat untouched for over twenty years because the region couldn't fund it -- a textbook case of how a signed ROD doesn't guarantee construction.  Technically is is still untouched -- HRBT Expansion is an alternative that was unselected in that study. 

Eh, I'm not so sure it's "standard practice."  Certainly isn't here in NY, where projects over $50m are commonplace.  You can also see all the projects currently in construction across the country; I'd be very surprised if most states have projects sitting on a shelf that have FEISes aging away, wasting the funds that were expended on them.

I won't repeat the incentives I mentioned already for project sponsors to not shelve projects at design approval.

Time will tell.

[Beltway]

Eh, I'm not so sure it's "standard practice."  Certainly isn't here in NY, where projects over $50m are commonplace.  You can also see all the projects currently in construction across the country; I'd be very surprised if most states have projects sitting on a shelf that have FEISes aging away, wasting the funds that were expended on them.
I won't repeat the incentives I mentioned already for project sponsors to not shelve projects at design approval.
Time will tell.

The examples I'm talking about aren't routine $50–200 million state jobs. They're multi‑billion‑dollar megaprojects, and the sequencing on those really is different. NEPA moves early because it's proportionally cheap and keeps options open; the funding fight comes later, and plenty of ROD‑cleared projects have sat for years when the money didn't line up. THRC CBA 9 is a perfect case -- full NEPA in 2000, and it went nowhere for two decades. That's the scale MDTA is dealing with. Time will tell, but the pattern is well‑established.

[Rothman]

Eh, I'm not so sure it's "standard practice."  Certainly isn't here in NY, where projects over $50m are commonplace.  You can also see all the projects currently in construction across the country; I'd be very surprised if most states have projects sitting on a shelf that have FEISes aging away, wasting the funds that were expended on them.
I won't repeat the incentives I mentioned already for project sponsors to not shelve projects at design approval.
Time will tell.

The examples I'm talking about aren't routine $50–200 million state jobs. They're multi‑billion‑dollar megaprojects, and the sequencing on those really is different. NEPA moves early because it's proportionally cheap and keeps options open; the funding fight comes later, and plenty of ROD‑cleared projects have sat for years when the money didn't line up. THRC CBA 9 is a perfect case -- full NEPA in 2000, and it went nowhere for two decades. That's the scale MDTA is dealing with. Time will tell, but the pattern is well‑established.

Heh.  I misread that first sentence.  Posting from bed again...

How does NEPA approval keep options open when it limits environmental screening to the preferred alternative?  It's true that aspects of the project can change, but you're limited to the parameters of the FEIS/ROD, or you have to supplement the EIS and no one wants to do that, whether the sponsor or FHWA.

Simplest example is deciding that the bridge you got to design approval has been deemed to narrow and you want to widen it.  That triggers more ROW takings and probably goes beyond the area screened for NEPA.  You can go smaller, but not bigger.

Best way to keep options totally open is actually not to obtain NEPA/design approval, which forces you to choose a preferred alternative -- to choose your option.

I still come back to the financial and process drawbacks of shelving a project as just not being worth the resources.  I suppose MDTA may have had funding to burn given their facilities.  But, again, despite the instances you've mentioned, where projects evolved over decades, my experience is that it's hard to believe they're the majority rather than the minority of megaprojects that get to FEIS given the mentality of DOT executive management and even gubernatorial chamber that I've been aware of.

I mean, appeasing the public on projects that are unlikely to proceed due to prioritization, including inadequate funding, is really the realm of pre-engineering studies, rather than scoping and I-IV and getting to design approval.  I LOL'd when Gov. Andrew Cuomo was touting his assistance to the North Country in NY in one of his State of the State speeches, building up his intentions, mentioned the Rooftop and then boomed, "So we will conduct another study!"  In that regard, there are definitely hundreds of studies of corridors, areas on all sorts of scales that are sitting on shelves collecting dust with their project recommendations.  Or, like the Rooftop or some places on Long Island that have study after study done repetitively but don't go any further. You throw some money at a study, rather than starting formal scoping or engineering.  And then, there's good reason why a lot of discussions on the forum surround someone finding an illustrative project in a STIP and their excitement is then tempered...

Speaking of that, I took a glance at MDOT's STIP and it states it's waiting for the FEIS to be completed on this.

End of the year could be quite fun, indeed.  MD will either look like they've thought this through or totally incompetent.

[Beltway]

The "options open" point isn't about redesigning the preferred alternative after the ROD -- you're right that going bigger triggers supplemental NEPA and nobody wants that. What NEPA buys you on a megaproject is programmatic optionality, not geometric flexibility. Once you have a cleared corridor and a selected alternative, you can pursue funding, P3 structures, phasing strategies, and delivery methods without having to restart the entire environmental process. That's the part agencies are trying to preserve.

And on the shelving question, I'm not arguing it's ideal -- just that it's common at the multi‑billion‑dollar scale. The executive‑level mentality you're describing is exactly why so many FEIS/ROD projects stall: leadership changes, priorities shift, and the money never materializes. CBA 9, Brent Spence (pre‑IIJA), I‑94 East‑West, Garden Parkway -- all cleared, all sat for years. That's the pattern MDTA is up against.

End of the year will tell us a lot, but the sequencing here isn't unusual.