VI. SUMMARY FINDINGS AND RECOMMENDATIONS status planes... · VI. SUMMARY FINDINGS AND RECOMMENDATIONS The following is a summary of the PMOC’s findings and recommendations for the

Departamento de Transportación y Obras Públicas (DTOP) Page 71 of 276 Puerto Rico Management Capacity and Capability Review June 2016

VI. SUMMARY FINDINGS AND RECOMMENDATIONS

The following is a summary of the PMOC’s findings and recommendations for the technical capacity and capability review of the transit agencies responsible for public transportation services in the Commonwealth of Puerto Rico. These are the PMOC recommendations, but it is the grantee’s decision on how to create their organization.

Due to the limited information received from each of the Grantees, the Management Capacity and Capability review was limited to PMOC observations during site visits, documentation received either during those site visits or during the staff interviews. This review is a snapshot in time recognizing that ultimately all three agencies will be in integrated into one transportation authority. Staffing plans were not provided for review, and the agencies history of performance for financial stability and implementation of management systems has been poor.

Review and evaluation of financial capacity, cost and schedule controls, procurement, land acquisition, community relations, Civil Rights, DBE, and ADA, were limited due to the PMOC’s constrained budget and schedule as well as overall financial crisis for the commonwealth which affects each agency’s ability to efficiently operate, hire qualified technical staff and update and maintain processes and procedures,

ATM: The PMOC performed reviews of operational, maintenance, management and organizational documents, interviewed key staff in the organization, conducted on-site visits and performed tours of the ATM facilities and vessels during August and September 2015. Based on these reviews, it is the PMOC’s opinion that ATM has the required technical capacity and capability to operate a safe ferry system and meet FTA grantee requirements. There are however a number of improvements that should be made for that opinion to continue in the future.

ATM has the required management capacity and capability due to its competent executive management. Significant improvements have been made in the areas of maritime operations, maintenance and repair, regulatory body compliance, and business processes and procedures. However, ATM has been unable to overcome long term weaknesses in ATM’s organizational structure; a lack of funding; and reactionary operational and maintenance practices. It is the PMOC’s opinion that with its current leadership and continuing support from the Commonwealth of Puerto Rico Government and FTA, ATM will continue to strengthen those functional areas within the organization that have been persistently weak.

In addition, ATM (thru the Puerto Rico Public-Private-Partnership (P3) Authority) is developing an RFP for a third party contract to operate and maintain the ferry services. FTA and the PMOC have provided comments and recommendations in the current O&M procurement, and has made clear to ATM that it is the grantee’s responsibility to ensure compliance with all FTA requirements. FTA is concerned that the P3 Authority’s apparent rush to release an RFP, might result in missing some FTA requirements. Should this contract operation scenario come to fruition, ATM has very little oversight technical capability.

The PMOC makes the following recommendations with regard to ATM:

• In order to address the organizational shortcomings identified, it is the PMOC’s recommendation that ferry operations be split up into three departments: marine/ferry


operations, M&R, and ferry services. Each department having a manager with equal stature, but all reporting to an overall general manager.

• ATM should consider the benefits that career employees bring to the core positions within the agency. o Extensive transit experience. o Wide-ranging technical knowledge in the core function. o Corporate knowledge in times of change.

• Develop and execute a succession plan for the current Executive Director. Currently, the incumbent has dual responsibilities within PRITA and ATM that will result in a less than optimal management at both organizations.

• During the transition of ATM into PRITA, consider how better to organize the agency to meet current and future challenges, operating requirements and scenarios, and strategic planning. Specifically, there is a need for a strong General Manager and Manager of M&R.

• Develop a strategic plan for future ferry crewing. This plan should include discussions with representatives of the USCG and budget for training and certifying seamen by external maritime training centers.

• Develop a plan and methodology to improve working relationships among the various functional organizations.

• It is clear that ATM management and its unions don’t always work effectively together. The PMOC recommends that improved relations with the unions become a management priority.

• Formalize a process for training, certifying and promoting mariners.

• Continue to report and deliver to the PMOC the operations data on performance measures included in Table 3 of this report. Achieve the performance goals and maintain performance above these goals.

• Develop a plan for the future use of the water taxi consistent with FTA requirements and the remaining federal interest.

• Develop a plan for the eventual replacement of the two catamarans.

• Continue to closely monitor and provide input to the P3 Authority’s procurement process. Ensure that the final procurement documents effectively protect federal assets and continue to allow PRITA/ATM to receive FTA grant support.

• Continue to fully implement a formalized PM and maintenance management system.

• Provide the PMOC monthly updates of the matrix listing of all required certifications and permits for all vessels.

• Report and deliver to the PMOC the maintenance data on performance measures included in Table 3 of this report, achieve the performance goals and maintain performance above these goals continuously.


• Continue to provide the necessary resources to meet federal and local regulatory requirements for safety and security.

• Designate a person or persons within the organization as the point(s) of contact for the USCG for all potential safety and security issues: inspections, investigations, pollution, mass casualties, port security, etc. Have that/those individual(s) contact their USCG cohort in order to establish and maintain a professional relationship.

• Obtain technical assistance in the development of processes and procedures for oversight of operation and maintenance services.

• Develop and gain approval of a financial plan to match any new ferry construction plans, ongoing dry-docking and refit programs, and any shore-side improvement plans.

• Ensure full implementation of the recently adopted PRPA procurement acquisition regulations.

• Complete implementation of the automated inventory system, and its integration with the purchasing and financial systems.

• Develop formal training and certification criteria and procedures to meet future USCG and organic requirements.

• Execute the plans to automate the reservation and fare purchasing systems allowing ATM to more accurately capture ridership and revenue data.

• Update the FMP, and develop a Safety Management System for the fleet.

AMA: The PMOC performed a management capacity and capability assessment of AMA, including observation of current AMA functions and interviews of key staff. Although AMA does have the required management capacity and capability, the lack of procedures, performance measures and oversight limit AMA’s ability to meet FTA’s requirements for technical capacity and capability is a concern. AMA is an organization that has long been in a state of flux due to the continuous turnover of key staff. Overstaffing, a no terminations policy, and reduced funding has led to a reduction of scheduled bus service and declining system performance. With the service route reductions, significant uncertainty exists as to the continued viability of AMA as a provider of fixed route and paratransit service in the San Juan metropolitan area. Due to the current financial crisis, AMA lacks the resources to improve the operations to the desired service levels and staff are not fully monitoring all appropriate aspects of the bus operations. Funding limits have also affected parts availability, training and creditability with vendors.

It is also the PMOC’s opinion that the transfer of many or most of the AMA functional management to PRITA will be challenging. PRITA will need to demonstrate that they will establish and maintain an effective management oversight environment, addressing the concerns in AMA’s practices. PRITA will need to ensure that they are prudently managing funds to demonstrate and document improvement in the performance of service through the contract compared to the performance of recent years. It is the PMOC concern that due to due to the high number of staff in the PRITA organization, available funds may not be sufficient to cover the bus operational expenses. It is the opinion of the PMOC that AMA service and PRITA would


benefit greatly by recognizing the potential for sustaining the status quo and implementing the recommendations below.

The PMOC recommends the following actions with regard to AMA:

• AMA should consider the benefits that career employees bring to the core positions within the agency. o Extensive transit experience. o Wide-ranging technical knowledge in the core function. o Corporate knowledge in times of change.

• The PMOC review found that while some current positions are filled by long term experienced personnel, others have backgrounds that do not necessarily fit their current responsibilities.

• AMA should conduct a comprehensive review of its core positions to determine what level of expertise and experience is needed to properly serve the Agency. Career track positions would also help to establish qualified persons to meet specific functional job descriptions today and in the future.

• AMA should adequately address all of the functions as identified in Table 7 - Current AMA Functions.

• AMA should update the Bus Fleet Management Plan and financial systems; and develop a Safety and Security Plan.

• AMA should implement a Daily Fleet Status Report, and conduct a senior management level review routinely. Included in the report should be pull-outs, vehicles out of service by category, in-service failures (miles between road call or similar), and status of repairs/availability of parts, etc. Many performance standards are available from other US bus transit agencies.

• AMA should implement a Monthly Progress Status Report for submission to the FTA prior to the regularly scheduled monthly meetings which includes graphs of daily performance measures (cost per vehicle mile, or similar standards as tracked in the National Transportation Database) for both fixed-route and paratransit service, tabulation and explanation of out-of-service vehicles, status of inactive fleet (progress for retirement), planned performance for the next month and the balance of the fiscal year (goals/standard to be achieved) and actual performance versus the plan.

• For AMA to improve its operations, it should establish performance standards, communicate them to employees and actively monitor those standards. There should also be more cross-training of staff.

• AMA should adopt a “Beat the Target” mentality on performance measures. This mentality is extremely important for the maintenance activities, but can be applied to the transportation operators and support departments as well. Charter those performing the work to meet the performance targets and communicate the results on a daily basis.


• AMA should adopt a “Customer First” mentality for the entire organization. Communicate a customer chain from each employees function through to the ultimate customer – the bus or paratransit rider.

• Re-train staff who are not performing adequately to gain the skills to achieve performance standards.

• In order to better define and communicate necessary actions by all employees, adopt the Four P’s – Policy, Plan, Procedure, and Process. Policy as set by top management; Plan as a set of actions to implement the policy; Procedure to further define specific actions in a step by step of how to do it; Process as the actual work performed by carrying out and/or interpreting the procedure. This method is particularly effective in doing operations and maintenance plans and SOPs or can be used to assist in creating job descriptions and training programs.

• The PMOC recommends that the newly defined core functional positions as illustrated in Figure 4 remain within AMA as they are envisioned as essential to the successful operation of transit bus service in San Juan.

ATI: The PMOC performed a technical capacity and capability assessment of ATI in August and September 2015, including interviews of key staff and review of management processes and procedures. The loss of support from the GMAEC in 2009 as well as the technical consultant, SKANSKA in 2014, has had a number of serious negative impacts on ATI; there is no one to mentor ATI staff, no monitoring of train operations, no engineering support for capital projects, no QA/QC program and no one at ATI has any awareness of the structural integrity program. All of these are serious concerns and could impact the state of good repair and the operational viability of the TU system.

Throughout several governmental administrations, ATI/PRHTA has continued to rely on the expertise and engineering depth of consultant staff and this has been clearly reflected in the prior organization structure. With no other comparable industry on the island, ATI/PRHTA must either recruit off-island expertise or develop in-house staff. The conundrum is that staff that develop expertise in-house are attractive to off-island firms that can offer better salaries. ATI/PHRTA will have to resolve this difficult issue as part of any plan to effectively perform the oversight of the O&M Contractor of the TU system.

Currently, the ATI organization does not have the technical capacity needed to fully monitor all appropriate aspects of the TU operation including the oversight of the O&M Contractor, ACI, nor does ATI have the qualified staff or technical capacity to operate TU independently of an O&M Contractor. The ATI organization would benefit if all maintenance activities are under the direction of one manager, with support staff directly responsible for oversight in the field. ATI needs to provide the proper training and tools needed for staff to perform their field inspection effectively and should institute weekly meetings with the O&M Operator to discuss issues, concerns and upcoming activities. Minutes and action items should be developed as a result of these meeting, identifying responsible parties and dates for completion.

The PMOC recommends that in the interim and within the next six months, ATI/PRHTA retain an on-call General Management, Architecture and Engineering Consultant


(GMAEC) to provide technical support for the oversight of the O&M contractor, and engineering support for capital projects. The PMOC also recommends that ATI/PRHTA develop a plan of action with milestones or a timetable that lays out ATI’s strategy toward effectively building and implementing an organization with the technical capacity and capability to oversee TU operations in house inclusive of external technical consultants. The PMOC recommends the following actions:

• The PMOC recommends that ATI/PRHTA develop a plan of action with milestones or a timetable that lays out ATI’s strategy toward effectively building and implementing an organization with the technical capacity and capability to oversee TU operations in house inclusive of external technical consultants.

• The ATI organization would benefit if all maintenance activities are under the direction of one manager, with support staff directly responsible for oversight in the field. Additionally, ATI needs to reestablish oversight of those areas that are no longer being monitored, including train operations, QA/QC auditing and structural integrity inspections.

• ATI needs to provide proper training and tools needed for staff to perform their field inspections effectively and should institute weekly meetings with the O&M operator to discuss issues, concerns and upcoming activities. Minutes and action items should be developed as a result of these meetings, identifying responsible parties and dates for completion.

• Revise the ATI position descriptions to correctly describe the specific duties and responsibilities of the positions, including position qualifications and desired experience. Include in the position descriptions that staff are required to participate in rail industry technical peer groups and to acquire knowledge of industry developments in their specialized areas.

• Develop and execute a staffing plan to fill the vacancies in its organization; consider hiring qualified staff with prior rail transit management experience.

• Develop peer contacts at other rail properties.

• Retain an on-call General Management, Architecture and Engineering Consultant (GMAEC) to provide technical support for the oversight of the O&M contractor, and engineering support for capital projects. With a number of capital projects such as fare collection and control center upgrades as well as vehicle rehabilitation being planned or underway, this engineering support is critical.

• Provide notice to underperforming employees that they need to improve their job performance or be replaced. Provide those employees with the opportunity to attend training and mentoring programs to improve their performance.

• Provide a personnel retention plan. Consider combining positions and offering a higher pay structure to qualified staff.

• With the assistance of the PMOC, develop a list of potential training opportunities for staff; FTA has advised that federal funds are available for staff training.


• Develop and implement a program for overseeing train operations, including dispatching, and train crew performance.

• Resolve any outstanding items related to the Siemens warrantee agreement.

• Establish a plan to restore the four cannibalized vehicles to full operating service.

• Establish a plan to perform preventive maintenance work on the elevators and escalators.

• Develop a near term and long term capital plan that is required to keep the TU system in a state of good repair.

• Establish a stronger safety oversight and review process.

• Reinstitute a QA/QC program.

• Implement a structural integrity program for the guideway, tunnels and structures that is in accordance with industry standards. Ensure that ATI managers are aware of all structural integrity reports and issues.

• Review and update all management plans, including the SOPs, incorporating existing procedures and newly developed procedures.

PRITA As of July 1, 2015, LAW 123-2014 creating a new Puerto Rico Integrated Transport Authority (PRITA) went into effect. The law establishes a single mass transit agency for Puerto Rico, including the merger of Puerto Rico’s Maritime Transportation Authority and the Metropolitan Bus Authority. The new authority was created to reduce redundancy and complexity in decision-making processes associated with the planning, management and operation of public transport systems.

On July 1, 2015 ATM and AMA were officially absorbed into PRITA; the fiscal year 2016 state funds for both ATM and AMA are allocated to PRITA. Implementation of shared a services structure within PRITA has started and is ongoing.

Development of PRITA as an integrated transit authority is still in process. The initial organization included a core executive staff of approximately 40 employees, growing to a staff of approximately 143. This initial organizational chart provided by PRITA showed a high number of political appointed positions. PRITA has indicated that the organizational chart is being revised and the PMOC recommends that PRITA consider the benefits that career employees bring to the organization. In addition, 143 seems a high number of staff for the size of the operations. PRITA has indicated the revised PRITA organization chart includes more career positions in top administrative staff, and only maintains appointed political positions for staff directly assisting the CEO functions. Furthermore, the 143 proposed positions will be revised to reflect an oversight function.

The PMOC recommends that all career positions are in place, management systems implemented and functioning and SOP’s developed, approved and implemented prior to PRITA’s completion of the new FTA Grantee process. The PMOC recommends the following actions with regards to PRITA:


• PRITA should consider the benefits that career employees bring to the core positions within the agency. o Extensive transit experience. o Wide-ranging technical knowledge in the core function. o Corporate knowledge in times of change.

• Consider career positions for the key PRITA staff as shown in Figure 8 to ensure that the agency continues to operate effectively during political transitions and for the retention of knowledge.

• PRITA research prior history when ATM, AMA and ATI were under one umbrella and use the information to develop a process to ensure proper accountability of ferry, bus and train funds.

• The current Executive Director of PRITA does not have any prior transit operations and minimal transit management experience. The PMOC recommends that PRITA develop a General Manager position requiring at least 10 years of prior transit experience. This position needs to be a “career” position in lieu of a “trusted” position.

• The PRITA organization has a fatal flaw in that the QA position is not identified. The PMOC recommends that a QA manager and properly trained staff should be included in the PRITA organization to regularly audit ferry, bus, and train operations.

• PRITA indicates it is an “oversight agency”, but the number of staff in the organization seems high for the operations that are being provided compared to similar operations within the United States. The PMOC recommends that PRITA streamline the agency, reconsidering the number of staff being proposed, and consider the benefits of career positions.

• PRITA should upgrade their computer systems and train staff to work with the technology.

• PRITA should expand their management capacity and capability for all the modes, ensuring qualified staff for the oversight of all three transit modes.

• PRITA should have its own Title VI officer to monitor the various compliance items of the O&M contracts for ATM and AMA, as well as the future ATI organization.

• PRITA needs to confirm how O&M activities will be combined for the buses operated by AMA and First Transit.

• Provide the PMOC with all SOPs and PM procedures for all modes that PRITA will oversee.

• Demonstrate the implementation of a financial system in accordance with the FMOC findings and provide all necessary hardware, software and adequately trained staff.

• Demonstrate the implementation and sustainment of the FTA accepted procurement processes and procedures currently in use by PRPA.

• The PRITA organization chart has a group noted as “Porteadores Publicos” service manager consisting of 11 staff members. PRITA has been advised there cannot be


federal funds for private carriers. To ensure that federal funds are not used for “Porteadores Publicos” service, the PMOC recommends that financial controls be established to prevent Federal participation on these expenditures.

• In response to the PRITA New Grantee Application, Technical Capacity Questionnaire, the response to Technical Capacity question 9, (If applicable, how will the new grantee conduct maintenance oversight of sub-recipients, contractors, or lessees?) is inadequate. The current response does not provide a sufficient description regarding the appropriate oversight and proper technical qualifications are not highlighted. The PMOC recommends that PRITA correct these deficiencies.

• Provide the FTA with required plans, procedures and supporting documents to demonstrate PRITA compliance with the referenced federal documents. For example, provide your detailed Procurement Manual.

• Consider providing a budget for individual, system specific training, for the staff, to allow individuals to gain needed expertise.

• The PMOC is concerned that the consultant contracts will be cancelled due to lack of funding leaving PRITA without technical capacity. The PMOC recommends that PRITA develop short and long term plans to retain the required technical capacity and in-house expertise.

• Review the current bus operations of First Transit and AMA to determine the best implementation of bus service including maximizing the combined assets.

• Develop a recruitment and retainage policy commensurate with the necessary skilled positions.

Departamento de Transportación y Obras Públicas (DTOP) Page 80 of 276 Puerto Rico Appendix A Management Capacity and Capability Review June 2016

VII. APPENDICES

APPENDIX A - LIST OF ACRONYMS

ACI Alternate Concepts, Inc. ADA Americans with Disabilities Act AMA Autoridad Metropolitana de Autobuses APTA American Public Transportation Association ATI Alternativa de Transporte Integrado ATM Autoridad Transporte Marítimo BFMP Bus Fleet Management Plan CBA Collective Bargaining Agreements CFR Code of Federal Regualtions COI Certificates of Inspection DBE Disadvantaged Business Enterprise DTOP Departamento de Transportación y Obras Públicas DTPW Department of Transportation and Public Works EEO Equal Employment Opportunity FMO Financial Management Oversight FMP Fleet Management Plan FTA Federal Transit Administration FY Fiscal Year GMAEC General Management, Architecture and Engineering Consultant HEO Hermandad de Empleados de Oficina HVAC Heating, Ventilation, and Air Conditioning IT Information Technology M&R Maintenance and Repair MARSEC Maritime Security NTD National Transit Database NTSB National Transportation Safety Board O&M Operations and Maintenance OCC Operations Control Center OEM Original Equipment Manufacturer QA Quality Assurance QC Quality Control P3 Public-Private-Partnership P3A Public Private Partnerships Authority PM Planned/Preventative Maintenance PMO Project Management Oversight PMOC Project Management Oversight Contractor PR Puerto Rico PREMA Puerto Rico Emergency Management Agency PRITA Puerto Rico Integrated Transportation Authority PRHTA Puerto Rico Highway and Transportation Authority

Departamento de Transportación y Obras Públicas (DTOP) Page 81 of 276 Puerto Rico Appendix A Management Capacity and Capability Review June 2016

PRPA Puerto Rico Ports Authority PVR Peak Vehicle Requirement RFQ Request for Qualifications RFP Request for Proposal SOP Standard Operating Procedures SSPP Safety and Security Program Plan TU Tren Urbano UETC Unión de Empleados de Transporte de Cataño USCG United States Coast Guard

Departamento de Transportación y Obras Públicas (DTOP) Page 82 of 276 Puerto Rico Appendix B Management Capacity and Capability Review June 2016

APPENDIX B – TECHNICAL COMMENTS RECEIVED ON FEBRUARY 19, 2016

Item # Agency Agency Finding Discrepancy Discrepancy 1 Source Discrepancy 2 Source Mitigation Activity Name Required Action PMOC Response - March 30,

2016 1 ATM Technical "ATM was created in 2000 as an

operating agency (public corporation) under the Puerto Rico DTOP"

Executive Summary Section II, Sub-Part A (Background)

Should read: "ATM was created in 2000 as an operating arm of the State (public corporation), attached to the Puerto Rico DTOP"

n/a Concur. Report revised as recommended.

2 PRITA/ATM Organizational "Should this contract [P3] operation scenario come to fruition, ATM has very little oversight technical capability"

Executive Summary n/a PRITA organizational chart Obtain PRITA Board of Director and PROMB's approval of organizational chart, to include the position of O&M Oversight & Contract Admin., as an equivalent position is currently not available under ATM's approved organizational chart (see attachment 1). The PMOC did not identify a current resource within ATM that could execute these duties under the current functional organizational chart (see attachment 2).

Concur. This new position would provide effective and expert oversight of the O&M contract requirements. A person with General Manager type experience would be excellent in this position. The PMOC does not believe a resource of this caliber currently exists within ATM. This position has been added to the final report however the position was not included in the organizational chart (Figure 8).



2016 3 ATM Organizational "Ferry operations should be split

up into three departments: maritime operations, maintenance and repair, and ferry/customer services. Each department having a manager with equal stature, but all reporting to an overall general manager."

Executive Summary Section II, Sub-Section B (Findings and Observations) / "Deputy Executive Director of Operation and Service – Is a position that was developed and made permanent in 2013. Ideally, this person will maintain continuity in the leadership of ATM if changes are made at the Executive Director level for political or other reasons. The incumbent is a degreed engineer with extensive shore side design and manufacturing experience. He first came to ATM in 2006 as a ferry captain, and therefore, is a licensed mariner. His strengths include working with the PMOC in the development of operational and maintenance procedure documentation." At page 23, "Based on PMOC observations and interviews, the organizational structure has deficiencies, with blurred lines of responsibility, and a fractured chain of command. Many of the key staff do not feel empowered to either make substantive decisions, or to effectively manage perceived subordinates. There is a continual breakdown in communication and cooperation between those in charge of ferry operations and those responsible for ferry maintenance. These stakeholders have credible reasons for their differing priorities, but no one has

(1) PRITA organizational chart; or (2) ATM organizational chart

(1) Under an O&M contract scenario, obtain PRITA Board of Director and PR-OMB's approval of organizational chart, to include the position of O&M Oversight & Contract Admin., as an equivalent position is not currently available under ATM's approved organizational chart (see attachment 1) and this recommendation would then become moot. If the PMOC's recommendation need to be addressed under the current ATM structure, then amend the functional organizational chart (see attachment 2), to designate the position of Auxiliary Executive Director for Operation and Service and empowered to perform equivalent duties like a "General Manager". As the interpersonal relationship identified by the PMOC are due, in part, as the Assistant Executive Director for Operation and Service and the Special Aids to the Executive Director all have direct reporting to the Executive Director (see attachment 1), then address this situation on the functional organizational chart. As, also, the PMOC did not identify a current resource

Concur with the assessment and potential remedy. As stated in the previous item, the PMOC does not believe a resource of the appropriate caliber and experience exists with ATM. The PMOC recommends external recruitment. This position has been added to the final report however the position was not included in the organizational chart (Figure 8).



2016 been able to satisfactorily mediate this chasm." At page 24 (Rulebook and Operating Procedures), "Rulebook and Operating Procedures ATM does not have extensive or comprehensive rulebooks or written operating procedures for either the Island or Metro services. However, the PMOC has been working with ATM to develop both operating and maintenance policies and procedures. This effort continues with the Deputy Executive Director charged with their development and implementation."

within ATM that could execute these duties under the current functional organizational chart (see attachment 2), a determination would need to be made as to the resource that would be designated to perform these duties (whether internal or requiring external recruitment).



2016 4 PRITA/ATM Organizational "ATM should consider the

benefits that career employees bring to the core positions within the agency"

Executive Summary Section II, Sub-Section B (Findings and Observations) / "Leadership – The current leadership is strong, effective, and knowledgeable in the administration of the organization. However, this strong leadership does not translate into an effectively managed organization. There are management deficiencies throughout ATM. There is often a lack of management guidance, oversight and prioritization when conflicting decisions are being made by the operations and maintenance departments. Additionally, many in leadership and management roles do not feel empowered to make necessary decisions. The PMOC believes that there are skilled leaders and managers within the current organization; however they must be empowered to improve on their practices. Assertive leadership and a healthy and communicative work environment must be implemented and sustained. Organizational changes and clearer lines of responsibility and authority are necessary. An organization that is administered by an Executive Director, but managed by a General Manager would be a positive step in filling this management void. Other organizational changes will be discussed later in his report."


(1) Under an O&M contract scenario, obtain PRITA Board of Director and PR-OMB's approval of organizational chart, to include the position of O&M Oversight & Contract Admin., as a career employee.

Concur. Addressed in previous items. This position has been added to the final report however the position was not included in the organizational chart (Figure 8).

5 PRITA/ATM Organizational "Develop and execute a Executive Summary Section II, Sub-Section B (Findings n/a To be discussed, due to local No action.



2016 succession plan for the current Executive Director. Currently, the incumbent has dual responsibilities within PRITA and ATM that will result in a less than optimal management at both organizations." "This qualified endorsement of ATM’s management capacity and capability is primarily due to current management transition uncertainties as ATM moves under the PRITA umbrella, the status of a full implementation of preventative maintenance and equipment/spare parts inventory programs, and the lack of a full complement of operating procedures documentation."

and Observations) / "This qualified endorsement of ATM’s management capacity and capability is primarily due to current management transition uncertainties as ATM moves under the PRITA umbrella, the status of a full implementation of preventative maintenance and equipment/spare parts inventory programs, and the lack of a full complement of operating procedures documentation." Section II, Sub-Section B (Findings and Observations), B.5 Transition Plan - "ATM has become a part of PRITA, and any transition issues presumably are being addressed at the PRITA leadership level. As of October 2015, PRITA leadership will be providing further information on this plan. Of particular interest to FTA/PMOC is the succession plan for ATM’s Executive Director, who is currently double-hatted as the Deputy Executive Director of PRITA. It is the PMOC’s opinion that the dual responsibilities will result in a less than optimal management at both organizations, regardless of the individual’s capacity for both positions." Section II, Sub-Section C (Recommendation), C.1 Organization - "• Develop and execute a succession plan for the

unavailable resources.



2016 current Executive Director. Currently, the incumbent has dual responsibilities within PRITA and ATM that will result in a less than optimal management at both organizations."



2016 6 ATM Organizational "The PMOC recommends several

strategies and actions to strengthen the overall maintenance and repair program. • An M&R Manager at the same managerial level as the Maritime Operations Manager and Ferry/Customer Services Manager reporting to a general manager should be included in the organization. The technical capability does not currently exist within ATM. This type of resource might not be available for the salary available in Puerto Rico; however, a contractor could mentor existing ATM resources to eventually be effective in this important management position.• Leadership must facilitate better communication among functional managers. Lack of useful and effective communication is a fatal flaw in the current organization. The “three-legged” management model previously discussed will help to breakdown the artificial management barriers and assist the organization work in unison.• ATM would benefit from better planning of scheduled PM and having ferries available when taken out of service, rather than the current more reactive maintenance and repair approach. This recommendation is rooted in better communication and the

Section II, Sub-Section B (Findings and Observations), B.3 Maintenance

Section II, Sub-Section C (Recommendation), C.1 Organization - "In order to address the organizational shortcomings identified, it is the PMOC’s recommendation that ferry operations be split up into three departments: marine/ferry operations, M&R, and ferry services. Each department having a manager with equal stature, but all reporting to an overall general manager."

See above See above No action.



2016 institutionalization of reports that already exist.• Drydock planning should start with adequate time prior to the expiration of the Hull Inspection certification. Better planning, timely procurement documentation release, more accurate and complete work packages, will decrease overall maintenance costs and provide better availability of ferries. "



2016 7 PRITA Organizational "During the transition of ATM

into PRITA, consider how better to organize the agency to meet current and future challenges, operating requirements and scenarios, and strategic planning. Specifically, there is a need for a strong General Manager and Manager of Maintenance and Repair."

Executive Summary Section II, Sub-Section B (Findings and Observations) / "Maintenance and Repair Program – The PMOC’s primary concern with ATM continues to be its inability to sustain an effective maintenance and repair (M&R) program. Specifically, a fully implemented PM program has not been attained. ATM does have technical capability and capacity in this function, but the management of the PM effort, reactive repairs, drydock planning, and regulatory compliance must be elevated and given the necessary budget to succeed. It is the PMOC’s opinion, that the contract operation of the fleet with clearly defined M&R performance measures, may be the only method to ensure the federally funded assets are protected." Section II, Sub-Section C (Recommendation), C.1 Organization - "ATM should consider the benefits that career employees bring to the core positions within the agency. o Extensive transit experience.o Wide-ranging technical knowledge in the core function.o Corporate knowledge in times of change." And also "• During the transition of ATM into PRITA, consider how better to organize the agency to meet current and future challenges, operating requirements and


Obtain PRITA Board of Director and PR-OMB's approval of organizational chart, to include the positions of General Manager. The PMOC did not identify a current resource within ATM that could execute these duties. Under a scenario of an O&M contract, the position of Manager of Maintenance and Repair would not be required, but technical knowledge in ferry M&R should be considered when recruiting of the position of O&M Oversight & Contract Admin.

Concur. This position has been added to the final report however the position was not included in the organizational chart (Figure 8).



2016 scenarios, and strategic planning. Specifically, there is a need for a strong General Manager and Manager of M&R."

8 ATM Human Resources

"Develop a strategic plan for future ferry crewing. This plan should include discussions with representatives of the United States Coast Guard (USCG). Formalize a process for training, certifying and promoting mariners, and include the necessary budget for training at external maritime training centers."

Executive Summary Section II, Sub-Section B (Findings and Observations) / "The PMOC strongly recommends the implementation of a curriculum of formal, required, and recurrent training for all mariners in ship operating and safety systems." Section II, Sub-Section C (Recommendations), C.1 Organization - "• Develop a strategic plan for future ferry crewing. This plan should include discussions with representatives of the USCG and budget for training and certifying seamen by external maritime training centers." Section II, Sub-Section C (Recommendation), C.2. Operations"It is the PMOC’s opinion that the ferry crews do not take ownership and pride in their vessels. Many ferry captains and crew members are unfamiliar with the various ship systems and operating procedures aboard the ferries that they operate. The PMOC recommends ATM implement the following actions:• Formalize a process for training, certifying and promoting mariners."

ATM's Human Resources Under an O&M contract scenario, this issue would become moot. In the meantime, while ATM operates the ferry service, work with PMOC/USCG on assignment of funding and coordination for required training by USCG approved courses and providers.

Although under an O&M contract the responsibility may revert to the contractor, the issue does not disappear. ATM will need to ensure that the final contract includes the requisite language and that ATM provides the appropriate oversight. No change was made to the report.



2016 9 PRITA Human

Resources "Obtain technical assistance in the development of processes and procedures for oversight of operation and maintenance services."

Executive Summary n/a PRITA's Human Resources See comment to item 2. Concur. Addressed in previous items. This position has been added to the final report however the position was not included in the organizational chart (Figure 8).

10 ATM Technical "ATM is not a federal grantee at this time."

Section II, Sub-Section A (Background)

n/a Should read: "ATM is not a federal grantee at this time, but rather a sub-grantee."


11 ATM Technical "Several issues contributed to the decision to abandon the route including: navigational hazards in the channel to the terminal especially after strong thunderstorms causing damage to ferries, lack of dependable service, causing extremely low ridership, and ATM transfer of the property to the Puerto Rico Convention District Center resulting in losing control of the facility."


n/a Should read: "Several issues contributed to the decision to abandon the route including: navigational hazards in the channel to the terminal especially after strong thunderstorms causing damage to ferries, lack of dependable service, causing extremely low ridership, and the transfer by several local agencies of the property and fixed assets to the Puerto Rico Convention District Center, and in turn to a private entity, resulting in losing control of the facility.




2016 12 ATM Technical "The Executive Director of ATM

is responsible for all maritime operations including ferry terminals, and the Isla Grande Maintenance Base located in the Santurce section of San Juan."


n/a Should read: "At times, two (2) Executive Directors have been responsible for all maritime operations including ferry terminals, one by each service. Under this scenario, but in the case of the Metro Service, the Executive Director assigned to the Metro Service was also responsible for the Isla Grande Maintenance Base located in the Santurce section of San Juan. At present, however, the Executive Director of ATM is responsible for all of these operations and facilities."

n/a Concur with some of the information provided; however, the timeframe that there were two Executive Directors was during a previous Puerto Rico government administration, was during a period of multiple changes, and lasted a short time. Prior to this time there was only one Executive Director in charge of all operations for several years. It is the opinion of the PMOC that the recommended language does not clarify or add value to the report; therefore, will not be included in final report.



2016 13 ATM Documentary "With regards to ATM’s

documentation, it is the opinion of the PMOC that ATM does not have a full complement of documents that an operator of its size would be expected to have in order to effectively and efficiently operate."

Section II, Sub-Section B (Findings and Observations)

Section II, Sub-Section B (Findings and Observations), at B.5. Plans and Procedures (Procurement Procedures and Policy) - "In response to a finding from the FTA Financial Management Oversight (FMO) contractor review, ATM has officially adopted PRPA’s “Reglamento Para La Adquisicion De Equipos, Materiales y Servicios En La Autoridad De Los Puertos” (Regulation for the Acquisition of Equipment, Material and Services for the Ports Authority). As indicated by its title, the document describes high-level procurement policy, and details specific responsibilities and authorities for the various dollar level acquisitions for PRPA and ATM."

Processes and procedures ATM's Finance and Administration is currently adapting the 13 desk reference procedures provided by the FMOC, and supplemented by PRITA to meet local regulation, to ATM's current available resources. ATM's Finance and Administration is also working on adapting the P.R. Ports Authority's procurement manual for this same reason (pending its adoption, it is being followed by ATM). From an operational perspective, ATM could make use of the PMOC's technical assistance to collect and/or draft all other processes and procedures. With respect to collection of drawings for the vessels, ATM has already obtained copies that are locally available by USCG Sector San Juan and have quotes from the vessels' builders (except for M/V Caribeña - VT Halter).

Concur. Will modify some of the language that more accurately describes the use of FMO and PRPA processes.



2016 14 ATM Technical "Of the personnel interviewed, the

only position that at the time of the interview, was moved to PRITA was "Director of Human Resources and Labor Relations."


Table 2 of Section II, Sub-Section B (Findings and Observations) ("Director of Human Resource and Labor Relations" should read "Manager of Human Resources and Labor Relations"

Should read: "Of the personnel interviewed, the only position that at the time of the interview, was requested to assist PRITA, while continuing her duties as an employee of ATM, was the Manager of Human Resources and Labor Relations. Under the description for the position under page 21, should read: "Manager of Human Resources and Labor Relations"

n/a Concur. Title will be revised from Director to Manager.



2016 15 ATM Organizational "According to the charts, ATM

has approximately 207 employees (the Deputy Executive Director of Human Resources position is filled and the Facility Security Officer is not included on the organization charts) as follows: • Executive Director’s Office – 6 • Administrative and Finance Departments – 10 • Island Service (Fajardo) – 102 • Metro Service (Isla Grande) - 87 As ATM is transitioning into PRITA, there is no longer a clear number of approved billets solely for ATM. Within the past two years, ATM’s employee count has been as high as 212. The Executive Director stated that there are several open billets within ATM, and that surplus personnel from AMA could be a source to fill several openings. However, as of October 2015, there have been no transfers between AMA and ATM."


n/a Should read: "According to the charts, as of December 17, 2013, ATM has approximately 207 employees (Human Resources Department, General Services under Finance and Administration, transferred from AMA, and the Facility Security Officer is not included on the organization charts) as follows: • Executive Director’s Office (Political Appointees)– 6 • Auditor's Office- 2 • Administrative and Finance Departments – 11 • Island Service (operational)(Fajardo) – 97 (excluding transferred from AMA) • Metro Service operational (Isla Grande) - 72 (excluding transferred from AMA) As ATM is transitioning into PRITA, there is no longer a clear number of approved billets solely for ATM. Within the past two years, ATM’s employee count has been as high as 220. The Executive Director stated that there are several open billets within ATM, and that surplus personnel from AMA could be a source to fill several openings. As of January 15, 2016, there have been 22 transfers between AMA and ATM."

Update and supplement functional organizational chart, to include all personnel as of 29-Feb-16

Concur; however, will need ATM to provide updated functional organizational chart.



2016 16 ATM Organizational "It is recommended, however, that

ATM include the Facility Security Officer in its organization chart."

Section II, Sub-Section B (Findings and Observations), at B.4. Safety and Security

n/a n/a See Above No change to report made.

17 ATM Technical At page 22, from "Maintenance Manager", should read "Maintenance Supervisor - Island Service"


n/a n/a n/a No change to report made.

18 ATM Plan "The Fleet Management Plan is out of date and should be updated in conjunction with the development of a fleet safety management system. Some of the data required for inclusion in these documents are:"

Section II, Sub-Section B (Findings and Observations), at B.5. Plans and Procedures

n/a n/a Obtain technical assistance from PMOC in developing Fleet Management Plan, or contract for external services.

No change to report made.

19 ATM Plan At this time ATM does not have a financial plan that shows how the updates to the fleet and shore facilities will be funded.

Section II, Sub-Section B (Findings and Observations), at B.5. Financial Plans and Capital Improvement Plan

n/a n/a Contract for external service to prepare financial plan; if 5 and 10-yr cash flow reports prepared by Conway is not sufficient for this purpose.

No change to report made.



2016 20 ATM Technical "ATM’s reservation, ridership

count, and fare collection are antiquated manual systems potentially subject to multiple sources of human error. Although there have been plans to upgrade and integrate these systems with other transit modes in Puerto Rico, little progress has been made over the past nine years."

Section II, Sub-Section B (Findings and Observations), at B.5. Recent Ridership and Fare Revenue Data

n/a Should read: "ATM’s reservation, ridership count, and the Metro's fare collection are antiquated manual systems potentially subject to multiple sources of human error. Although there have been plans to upgrade and integrate these systems with other transit modes in Puerto Rico, little progress has been made over the past nine years."

Due to funding issues, have been unable to purchase all required hardware (printers and scanners) to: (1) publish the webpage for purchases of tickets via Internet; (2) print individual (not grouped) tickets; (3) scan tickets (and reconcile sales to actual passengers onboard; and (4) extend the Island service's ticketing system to Metro (pending implementation at Metro service of the integrated ticketing system).

Concur, will add additional information; however, the original language is still accurate.

21 ATM Operation "Develop a plan for the future use of the water taxi consistent with FTA requirements and the remaining federal interest." and " Develop a plan for the eventual replacement of the two catamarans"

Section II, Sub-Section C (Recommendations), at C.2. Operations

n/a n/a Develop plan to modify La Decima into a support vessel; or install at Catano terminal a divide that would allow ADA compliance. Conway's 5-yr and 10-yr cash flow considers fleet replacement funding for replacement of Amelia and Covadonga.

Concur, will add additional information; however, the original language is still accurate.


Item # Agency Agency Finding Discrepancy Discrepancy 2 Source Mitigation Activity Name PMOC Response - March 30, 2016

1

ATI/PRHTA Not clear who is monitoring and reviewing structural integrity program on the TU guideway, tunnels and structures.

In Amendment #4 of O&M Contract waived the operator of this responsibility and the inspection report is now responsibility of the Authority's Bridge Inspection Division (Exhibit I)

Page 57 of 2012 ATI/PHRTA has not been able to provide documentation of a structural integrity program for Tren Urbano fixed structures. Program should comply with APTA Standard RT-FS-S-001-02 - Standard for Rail Transit Structure Inspection and Maintenance, 49CFR Part 237 Bridge Safety Standards and other appropriate US standards.

2

ATI/PRHTA ATI position descriptions do not accurately describe the duties and responsibilities of the positions

When ATI was created, the Human Resource Division did not create alternate nor specific positions or job descriptions with the requirements needed for the transit and intermodal personnel.

Page 57 of 2012 This will be addressed through PRITA

This should be addressed prior to filling any positions at ATI.

3

ATI/PRHTA ATI organizational chart do not accurately describe the duties and responsibilities of the positions.

Duties and responsibilities are not ordinarily included in an Agency's organizational chart. If really required, we will address

Page 57 of 2012 Recommend that ATI job titles reflect the duties and responsibilities of the position.

4

ATI/PRHTA None of the ATI staff interviewed had any experience in rail transportation prior to joining ATI/PRHTA; they developed their knowledge and skills through a mentoring program with GMAEC. Since the GMAEC contract ended and has not been renewed, there is no mentoring program available.

Last amendment for GMAEC contract is Amendment #22 dated October 2006. In said amendment, it was clear that GMAEC's one of five main objectives was to continue serving as an agent to PRHTA in monitoring the delivery of the Tren Urbano revenue service while training and mentoring ATI management staff to facilitate the transfer of operations oversight from GMAEC to ATI. The 2009 Contract with Skanska does not include training as part of the responsibilities/scope of work.

Page 58 of 212 ATI/PRHTA shall develop a recurrent training program that clearly establishes which credentials are needed by each position and how often is required to take the courses.

Mitigation activity does not address the recommendation. Courses are insufficient. Inexperienced ATI staff need the support of knowledgeable, experienced support staff (GMAEC) to mentor them in order to gain practical knowledge of the system that they oversee.



5

ATI/PRHTA ATI/PRHTA issued a new RFP for an O&M Contract; however delays resulting from bidders protests have put the planned award date in jeopardy.

ATI/PRHTA completed the RFP process and ACI/Herzog was selected as the successful bidder. ATI/PRHTA is currently in the process of developing contract language for contract execution. The process was contested by First Transit and Legal Advisors are currently analyzing the protest.

Page 58 of 212 Comment will remain open until the new contract is completed and signed.

6

ATI/PRHTA Under the one year maintenance contract extension, the elevator/escalator subcontractor is providing on call repair service but no preventive maintenance to the equipment

The contract extension to ACI does not changes/modifies this contract clause. It is said in the amendment language that all other clauses were to remain . Currently, Schindler has a contract with ACI to provide preventive and corrective maintenance for escalators and elevators. In response to comments in page 58 of 212 in part B.2 Operations and Maintenance. Evidence will be submitted as requested. This contract is All inclusive.

Page 58 of 212 Subcontractor Monitoring and Compliance

Discrepancy information is at variance with information provided to the PMOC by ATI staff. Either information is inaccurate or the contractor is not providing the required PM service as per contract.



7

ATI/PRHTA ATI/PRHTA has not resolved all warrantee issues with Siemens. This issue, combined with poor management of spare parts availability has resulted in "cannibalization" of four vehicles.

We have no problems with the guarantees. ATI's position is that if operators use a replacement part and not an original piece, the warranty would be void. Cannibalism is performed by the operator as it does not want to assume the cost of the piece, as it is too expensive to pay for new parts. The TU is unique and therefore only the parts are manufactured by Siemens. In order to produce the parts that make faults, the manufacturer needs to produce for other system and produce only for ours. This makes the parts more expensive. The Authority sent letters to the operator to cease this practice, but the operator continues.

Page 58 of 212 1. Spare part inventory for preventive and corrective maintenance activities. 2. Review Maintenance Plan in order to assure consistency with new O&M Contract

ATI/ACI has been requested to provide a list of parts that are still under Siemens warrantee, indicating the warrantee end date for each part.



8

ATI/PRHTA It does not appear that the a workplace safety program has been implemented for TU encompassing occupational safety and health, injury and illness prevention, hazard communication, fire and life safety, emergency preparedness, operational safety, environmental, and security programs.

ACI has a written Occupational Safety Program which has been implemented as required by OSHA. ACI also has a System Safety Program Plan (SYSTEM SAFETY PROGRAM PLAN) which covers all System Safety and Environmental (content is outlined for each chapter). ACI currently complies with all environmental requirements as per SYSTEM SAFETY PROGRAM PLAN chapter 19. Examples are, air emissions permits, Storm Water Pollution Preventions Plan (SWPPP), Environmental Compliance Schedule for Air Emissions Permits, PRASA Car Wash Report. ACI has also a written Security Plan which is in schedule to be revised during this year, 2016, plus a Security and Emergency Preparedness Plan (SSEPP) which outlines all Security tasks for the System.

Page 59 of 212 ATI/PRHTA shall develop a Master Safety Plan for TU Operations. (The O&M Contractor shall provide its own Safety Plan based on this). The Master Safety Plan shall include, but should not be limited to, Transportation Safety, Vehicle Safety, Physical Plan and Maintenance Safety, Consistent training to staff, emergency responses and oversight and analysis of Tren Urbano hired police and security programs.

ATI staff including the ATI Safety Manager needs to have a clearer picture of ACI's current and planned safety program and should determine if the program complies with all appropriate standards.



9

ATI/PRHTA Evidence of an employee safety program to develop and communicate safety information to ATI employees, to heighten safety awareness, and to encourage the identification and resolution of hazards oversight and monitoring was not provided

Evidence of an employee safety program to develop and communicate safety information to ACI employees, to heighten safety awareness, and to encourage the identification and resolution of hazards, has been covered in both the Occupational Safety Program and the SYSTEM SAFETY PROGRAM PLAN. Another evidence of the preceding tasks is the Corrective Action Plan (CAPs) in which ACI reports events which requires further follow-Up and corrective measures and to heighten safety awareness. Tool Box meetings, Safety meetings and Safety Committee meetings are evidence of awareness on safety. Training certifications, safety and Security awareness trainings, are among other examples.

Page 59 of 212 A follow up meeting with ACI and ATI found that ACI safety reports only reference accidents, incidents and violations. Proactive safety items such as tool box meetings, safety awareness bulletins, etc. are not included in safety reports. Additionally, there does not appear to be any hazard management program documentation.



10

ATI/PRHTA Evidence of the performance of frequent and routine system and equipment inspection and audits of the ACI maintenance programs, aimed at identifying and eliminating hazards, was not provided.

ACI’s Safety Department performs routinely and frequent inspections to Stations, O&M Maintenance Shop, AED’s, Fire Systems, Elevators and Escalators, PA’s, Telephone system, tunnels ventilation system as per SYSTEM SAFETY PROGRAM PLAN, Train’s Preventive Maintenance, Operators Certifications which includes Line Controllers and Station Officials. We also have audits from ATI Safety Department and SSO on SYSTEM SAFETY PROGRAM PLAN and SSEPP implementation, all aimed at identifying and to eliminate hazards. Revisions to this data available upon request. Audits recommended by former consultant GMAEC for train control systems and traction power systems do not mention the use of meters or instruments in inspections to be performed by ATI employees. See Quality Assurance Quality Control Program and Procedures Development Manual submitted by former consultant GMAEC and procedures ATI.GP.00.02.04 (Audit – Train Control), ATI-TU.05.02.01 (Traction Power), ATI.GP.00.02.06.01 (Audit-Power) and other procedures. In response to comments for the Interim Facilities Manager located in page 55 of 212. Evidence will be submitted as requested.

Page 59 of 212 Develop and Implement Audit Program to oversight the O&M Contractor

Documentation of ATI Safety Audits to identify and eliminate hazards has been requested but has not been provided. Please provide specific audit documentation.



11

ATI/PRHTA The hazard identification and resolution process has not been established

The Hazard Identification and Resolution process for ACI has been established as per Chapter 6 on the SYSTEM SAFETY PROGRAM PLAN. Input to this process are the routinely inspections by ACI’s Safety Department, QA/QC, lesson’s learned from events investigations, internal audits. Recent modifications have been implemented to the CAP’s Report Form, as requested by ATI Safety Manager, on the monthly staff meeting between ATI staff and SSO. Audits recommended by former consultant GMAEC for train control systems and traction power systems do not mention the use of meters or instruments in inspections to be performed by ATI employees. See Quality Assurance Quality Control Program and Procedures Development Manual submitted by former consultant GMAEC and procedures ATI.GP.00.02.04 (Audit – Train Control), ATI-TU.05.02.01 (Traction Power), ATI.GP.00.02.06.01 (Audit-Power) and other procedures. In response to comments for the Interim Facilities Manager located in page 55 of 212. Evidence will be submitted as requested.

Page 59 of 212 A follow up meeting with ACI and ATI found that there does not appear to be a formal program documenting hazards identified, short term and long term mitigation and corrective actions and close out of the hazard.

12

ATI/PRHTA Many of the ATI staff reported having little to no interaction with the ATI Safety Manager.

More information is required for corrective action to take place.

Page 59 of 212 A frequent, ongoing relationship between the oversight engineers and the safety manager is important in identifying potential hazards before an accident occurs.



13

ATI/PRHTA ATI staff advised that the recommended maintenance provided in the maintenance plans is not being followed by ACI. ACI, by direction issued at least four years ago, is performing reduced maintenance.

That was the agreement in the Change Directive #29 to reduce cost. (Exhibit III)

Page 59 of 212 The reduced maintenance requirements implemented under Change Directive #29 to reduce cost could adversely impact the state of repair of Tren Urbano's facilities, systems and equipment.

14

ATI/PRHTA PMOC's analysis and opinion on Interim Facilities Manager

The years of experience and the years in current discipline of engineer José E. Morales González are 27.5 years. See Table 12 – ATI Staff Qualifications Experience

Page 54 of 212 The PMOC will correct Table 12

15

ATI/PRHTA ATI should institute weekly meetings with the O&M Operator to discuss issues, concerns and upcoming activities.

Both the Deputy Executive Director and The Office of Facilities and Systems have weekly meetings with the O&M Operator (ACI) to discuss issues, concerns and upcoming activities.

Page 62 of 212 ATI/PRHTA personnel moving to ACI's facilities. Documenting with detailed meeting minutes the items discussed.

The statement will be revised to reflect that meeting minutes and action item lists should be prepared for the weekly meetings.

16

ATI/PRHTA PMOC's analysis and opinion on Interim Operations Manager

The PMOC suggests that the Bachelor Engineer- Intermodal is responsible of reporting to the National Transportation Safety Board (NTSB). The responsibility of the BSE is with the National Transit Database (NTD) as specified in the resume.

Page 56 of 212 Report will be revised to reflect NTD reporting, not NTSB.



17

ATI/PRHTA PMOC's analysis and opinion on Interim Operations Manager

The employee does not agree with the following: They conclude and generalize that “the individuals developed their knowledge and skills through a mentoring program with GMAEC”. In my specific case, I developed skills and knowledge through FTA seminars and personal experiences.

Page 58 of 212 The discussion of the Interim Operations Manager does not include the statement, “…the individuals developed their knowledge and skills through a mentoring program with GMAEC” as stated in the Discrepancy column.

18

ATI/PRHTA Table 13, PMOC Recommendation by Position

A position of Intermodal Engineer in PRITA/ATI is recommended to the Bachelor Engineer- Intermodal. Need to check with the position requirements as it is ATI/PRHTA understanding that the person cannot hold a position as engineer because a BS is not a licensed engineer.

Page 63 of 212 The individual currently holds the position of Bachelor Engineer. On Table 13, the new title will be revised to reflect the individual's current title.



1

PRITA Revision "Until June 30, 2015, the transportation authorities attached to the DTOP operated as public corporations, which provide them with fiscal autonomy and administrative flexibility. However as of July 1, 2015, the law creating new Puerto Rico Integrated Transport Authority (PRITA) is in effect."

Executive Summary; p2; p64

Should read: "The transportation authorities attached to the DTOP (AMA, ATM, HTA) operate as public corporations, with their corresponding governing bodies and budgets, which provide them with fiscal autonomy and administrative flexibility. A new Authority called PRITA was created by Law 123 in August 2014 to implement the Commonwealth's public policy on transit and integrate transit operations, merging AMA and ATM, and transferring Tren Urbano operations. PRITA started its operations in October 2014. As of July 1, 2015, the state funds provided to support AMA and ATM transit operations were channeled through the new Puerto Rico Integrated Transit Authority (PRITA)."

Report revised with some minor changes to the wording.



2

PRITA Revision "In August 2015, the PMOC requested, received and reviewed the organization chart reflecting current PRITA organization; roles and responsibilities of what each functional unit is responsible for; job descriptions for each position listed in the organizational chart; resumes of incumbents in key positions; and current operating policies and procedures for each of the three transit agencies."

Executive Summary; p2 Should read: PRITA submitted a grantee application to FTA on July 2015 for the integration of bus and ferry services, that included an organization chart, roles and responsibility of functional units and presented existing AMA and ATM staff to cover essential functions, among other information. The grantee solicitation was based on the current scenario of direct operations of transit services and not oversight.

Report revised as noted.

3

AMA-PRITA Issue It is the PMOC’s opinion that the transfer of many or most of the AMA functional management to PRITA will be challenging. PRITA will need to demonstrate that they will establish and maintain an effective management oversight environment, addressing the concerns raised in AMA’s practices. PRITA will need to ensure that they are prudently managing funds while providing an improved level of service compared to the performance of recent years. It is the PMOC concern that due to the high number of staff in the PRITA organization, available funds may not be sufficient to cover the bus operational expenses.

Executive Summary: AMA; p4

Argument: The core staff presented in the PRITA grantee solicitation included administrative staff from both AMA and ATM; therefore the salaries of those employees are current expenses of transit administration and not additional expenses induced in the budget. The integration of AMA and ATM staff in PRITA will promote uniform and streamline management procedures and practices in accordance to required state and federal procedures. For example, PRITA approved the 13 FMOC procedures in its operation. The AMA and ATM staff integration is key to promote employee training and improve current practices to achieve effective management and administration of funds.




4 ATI Revision Santruce Executive Summary:

ATI; p5; p50 Replace word for Santurce Report revised as noted.

5

PRITA Revision As of July 1, 2015, LAW 123-2014 creating a new Puerto Rico Integrated Transport Authority (PRITA) went into effect.

Executive Summary: PRITA; p7; p64; p68

Correction: A new Authority called PRITA was created by Law 123 in August 2014. The first meeting of the Board of Directors was held in October 2014, therefore marking the start of its administrative operation. The PRITA Executive Director and executive staff started full-time in February 2015.


6

PRITA Revision On July 1, 2015 ATM and AMA were officially absorbed into PRITA

Executive Summary: PRITA; p7; p64; p68

Correction: As of February 2016, ATM and AMA continue to operate as separate public corporations. As of July 1, 2015, the state funds provided to support AMA and ATM transit operations are channeled through the new Puerto Rico Integrated Transit Authority (PRITA)."


7

PRITA Revision Implementation of shared services structure within PRITA has started and is ongoing.

Executive Summary: PRITA; p7; p68

Correction: A plan to implement a shared structure for AMA and ATM within PRITA was presented and Interagency Agreements to allow staff and resources collaboration were signed between the Authorities on July 2015. As of February, 2016, the implementation of the shared services structure within PRITA, or the movements of AMA or ATM employees, has not yet started.




8

PRITA Revision This initial organizational chart provided by PRITA showed a high number of political appointed positions

Executive Summary: PRITA; p7; p68

The statement is subjective indicating that a high number of political appointed positions is presented in the PRITA organization chart presented in the solicitation. Nonetheless, the updated organization chart includes more career positions in top administrative staff and only maintains appointed political positions for staff directly assisting the CEO functions for the implementation of public policy and strategic projects.

Comment noted however, no revisions made to the report.

9

PRITA Revision PRITA indicates it is an “oversight agency”, but the number of staff in the organization seems high for the operations that are being provided compared to similar operations within the United States.

Executive Summary: PRITA; p7

The 143 employees included in the PRITA solicitation were based on a hybrid scenario where both oversight and administration of O&M contracts (FT and ACI) and direct operations for buses and ferries services (AMA and ATM, respectively) exists. After the grantee solicitation was submitted, the scenario for PRITA was revised by executive decision to carry out only the oversight function of transit operations, therefore there is need to revise the PRITA grantee solicitation to reflect this new scenario.




10

Revision Due to the limited information received from each of the Grantees, the Management Capacity and Capability review was limited to PMOC observations during site visits, documentation received either during those site visits or during the staff interviews. Staffing plans were not provided for review, and the agencies history of performance for financial stability and implementation of management systems has been poor.

Methodology; p12 The report must provide the list of required information and received information from each grantee. Conclusions based on generic terms of "poor, bad, good, etc." should be avoided and should be better if they are sustained with information.


11

ATM Revision and the Isla Grande Maintenance Base located in the Santurce section of San Juan

Methodology; p12 Not located in Santurce, please review. Report revised. Period placed after 'Base'. Deleted: 'located in the Santurce section of San Juan.'

12

ATM Revision Of the personnel interviewed, the only position that at the time of the interview, was moved to PRITA was Director of Human Resources and Labor Relations

p14 The ATM Director of Human Resources and Labor Relations has assisted PRITA as requested during this transition period; but no transfer of ATM staff to PRITA has not yet occur as of Feb. 2106.

Report revised. Language changed.

13

ATM Revision This qualified endorsement of ATM’s management capacity and capability is primarily due to current management transition uncertainties as ATM moves under the PRITA umbrella

p15 PRITA was not created as an umbrella-type structure.

Report revised. The new statement reads: 'This qualified endorsement of ATM's management capacity and capability is primarily due to current management uncertainties as ATM moves toward integration into PRITA and the potential of the implementation of a P3 type operation and maintenance contract.'

14

ATM Revision However, as of October 2015, there have been no transfers between AMA and ATM.

p20 As of January 2016, 22 employees from AMA has been transferred to ATM to fill managerial and operational open positions.




15

ATM Revision ATM has become a part of PRITA p29 As of February 2016, ATM has not become part of PRITA.


16

AMA Revision AMA has implemented reduced scheduled service on its bus routes in coordination with its restructuring within the Puerto Rico Integrated Transit Authority (PRITA)

p34 AMA implemented a new service plan on August 2014 as a result of the current state of operations, resources and budget available. The planning and implementation of the new service plan was an independent activity from the development of PRITA.


17

AMA Revision It should be noted that most of the AMA management staff has changed at least once since early 2014.

p34 This statement is vague and overstates the actual quantity of AMA roster changes from 2013-2015 at the executive or top managerial positions. The previous AMA President and General Manager was in place from March 2013-January 2015, when he transferred to PRITA, as the then PMOC expressed concerns on the effectiveness of the person holding the two hats simultaneously. The only staff member that changed in the AMA organization during year 2014 was the VP of Human Resources in the month of November 2014.




18

PRITA Revision In addition, a meeting was held with PRITA staff and its consultant on September 3, 2015 to better understand the intent and process in creating PRITA as a functioning multi-modal agency within the DTOP.

p34 This statement seems to be out of place in the context of this section of the report as the meeting considered the state of the integration process in the solicitation. This meeting was result of a request made by PRITA and the external consultants to serve as a "exit meeting" with the PMOC after the interviews held at AMA, ATM, and ATI that took place earlier that same week. Out of the staff interviewed at AMA, only one was included in PRITA's solicitation exercising a core function to be transferred to PRITA.

Report revised and statement moved to the Executive Summary section.

19

AMA Revision In addition, the PMOC was not provided with a Safety and Security Plan.

p34 A Safety and Security Plan was developed and adopted by AMA in 2014, in conjunction with PMOC support and review.


20

AMA Methodology Set of questions used for the staff interviews at AMA

p37-41 Please clarify if different set of questions were used for the interviews of staff at AMA, ATM and ATI. The report does not specify this issue and if the answers were evaluated using the same criteria for the three corporations AMA, ATM and ATI.

A base set of questions were developed, which were revised and supplemented for the agency and mode being interviewed.

21

AMA Table 6 Cells with missing information p39 President should read 7 mo. As the time at AMA; Programming VP should read 2 yrs plus for Time at AMA and Time in Current Position; VP of Administration should read 15 yrs. Plus as Time at AMA




22

AMA Revision President and General Manager – the individual has held this position since February 2015. His previous position at AMA was external legal advisor for two years, which has not been backfilled.

p39 This individual served as external legal consultants to handle union cases and CBA negotiations for AMA from oct-2013 to june-2014. AMA had additional external legal contractors during the same period. Currently, external legal resources for AMA is being provided by consultants.


23

AMA Revision some have been stated to be held under PRITA while it is unclear if several others are adequately addressed

p42 This statement is vague as there was no opportunity for PRITA to clarify current/future roles of responsibilities within AMA operations. Currently, Safety and Security functions are direct responsibilities of AMA. Except for the Marketing/Government Relations functions that are supported by DTOP, the other support functions shown on Table 7 are current responsibilities of AMA


24

AMA Revision PRITA is currently applying for FTA grantee status in place of AMA as a separate entity.

p42 The PRITA solicitation included both AMA and ATM.

Comment noted however, no revisions made to the report since this section of the report is limited to discussing AMA.

25

AMA Revision the PMOC developed an AMA/PRITA Functions (Table 8) to visibly present all functions typically found in a bus transit operation

p42 The report is not consistent in analyzing the relationship of PRITA and AMA/ATM. The analysis/recommendations presented in Table 8 were not made for ATM, even though the same scenario could be also possible between ATM and PRITA.

Comment noted however, no revisions made to the report since this section of the report is limited to discussing AMA.



26

AMA Revision Table 9 - AMA/Contractor/PRITA Functions to visibly present all functions typically found in a bus transit operation but distributed between a skeleton “AMA” staff for managing the contractor, the Contractor, and PRITA as the umbrella oversight agency

p43 Need to clarify the implication of this statement. If the service is contracted, what is AMA’s role (it seems unnecessary) if the oversight and contract administration will reside in PRITA?


27 AMA Revision The Executive Vice President is “on loan” from

Department of Justice p44 Should read "Department of Corrections" Report revised as noted.

28 AMA Revision Of additional concern are the disposition of

federal assets with regards to AMA/PRITA finances.

p44 Not clear what the statement is referring to. Provide clarification.

This statement refers to the buses and any federal assets to be disposed of.

29

AMA/PRITA Recommendation PRITA will need to ensure that they are prudently managing funds while providing an improved level of service compared to the performance of recent years.

p49 PRITA is not envisioned to directly operate bus services as the vision is to procure a third party for O&M activities.


30

ATI Revision Deputy Exec. Director for Transportation - the individual advised that he had no prior experience in rail transportation before to joining ATI

p54 The individual has 10 years working with ATI and Tren Urbano; therefore the statement about not having experience prior to ATI might appear moot at this time.


31

ATI Revision He had no rail transportation experience prior to starting with ATI eleven years ago.

p55 The individual has 11 years working with ATI and Tren Urbano; therefore the statement about not having experience prior to ATI might appear moot at this time.


32 ATI Revision ATI/PRETA p58 Should read ATI/PRHTA Report revised as noted.

33

ATI Revision ATI/PRHTA has expressed the intention to eventually operate and maintain the TU system directly

p61 Please clarify is there is a recent official decision informed by HTA or if this is a comment from ATI staff members.

Prior to the establishment of PRITA, ATI staff has expressed this intention for the last few years.



34

PRITA Revision Implementation of shared a services structure within PRITA has started and is ongoing. There are approximately 60 staff members assigned to PRITA as of September 1, 2015

p64 No transfer of employees from AMA, ATM or HTA has occurred at this moment.

Comment noted.

35 PRITA Issue PRITA appears to have an excessive number of

positions for the size of its transit operations p64 Refer to comment 19. Comment noted however, no revisions made to

the report.

Departamento de Transportación y Obras Públicas (DTOP) Page 118 of 276 Puerto Rico Appendix C Management Capacity and Capability Review June 2016

APPENDIX C – RESPONSE TO PMOC RECOMMENDATIONS RECEIVED ON FEBRUARY 8, 2016

Item # Agency Technical Capacity Recommendation Page Reference Mitigation Activity Responsible

Party PMOC Response - March 30, 2016

1

ATM In order to address the organizational shortcomings identified, it is the PMOC’s recommendation that ferry operations be split up into three departments: marine/ferry operations, M&R, and ferry services. Each department having a manager with equal stature, but all reporting to an overall general manager.

3, 69-70 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry services (including the pending O&M Contract).

PRITA Latest organization chart dated February 17, 2016 provided for verification.

2

ATM ATM should consider the benefits that career employees bring to the core positions within the agency.

3, 70 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of all transit modes. This recommendation will be addressed in a two-fold approach; first, technical oversight consultants will be hired by PRITA through an RFP to immediately address any current gaps in technical capacity; second, these consultants will then train permanent replacements in the form of career local employees to perform these key oversight and management roles.

PRITA PMOC agrees with mitigation plan however the recommendation will remain open until contract is awarded and the GMEAC is given NTP. Provide a current timeline (month/year) to complete the first of the two-fold approach.




3

ATM Develop and execute a succession plan for the current Executive Director. Currently, the incumbent has dual responsibilities within PRITA and ATM that will result in a less than optimal management at both organizations.

3, 70 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry services (including the pending O&M Contract). The Manager of Maritime Services (fulfilled through the use of consultants in the Technical Oversight Support RFP and their later career employee replacement) of Manager of Intermodal Transportation for maritime transportation will absorb the operational functions of the ATM Executive Director role, while the Director of Transit Operations and PRITA General Manager (also filled through the Technical Oversight Support RFP and later career replacements) will address the service planning, managerial and budget elements of the ATM Executive Director position. The current ATM Executive Director will also transition to PRITA to provide continuity to ferry operations.

PRITA PMOC agrees with mitigation plan however the recommendation will remain open until contract is awarded and the GMEAC is given NTP. Provide a current timeline (month/year) to complete the first of the two-fold approach.

4

ATM During the transition of ATM into PRITA, consider how better to organize the agency to meet current and future challenges, operating requirements and scenarios, and strategic planning. Specifically, there is a need for a strong General Manager and Manager of M&R.

3, 70 The revised PRITA Organizational Chart includes the PRITA General Manager and Administrator of M&R in its structure. These roles will be filled with consultants from the Technical Oversight Support RFP and will later transition to appropriately trained and experienced local career employee staff.

PRITA Latest organization chart dated February 17, 2016 provided for verification.




5

ATM Develop a strategic plan for future ferry crewing. This plan should include discussions with representatives of the USCG and budget for training and certifying seamen by external maritime training centers.

3, 29, 70 Under the pending O&M contract scenario, this issue would become moot. In the meantime, while ATM operates the ferry service, work with PMOC/USCG on assignment of funding and coordination for required training by USCG approved courses and providers.

P3 Meeting current crewing needs will be the responsibility of the contract operator, but the PMOC has not seen any requirement that the operator must be concerned about potential future USCG crewing requirements. The PMOC recommends that PRITA/ATM, O&M Contractor, and USCG form an Integrated Product Team (IPT) that meets (at first) quarterly to discuss and formulate recommendations for action on any issues that may arise.

6

ATM Develop a plan and methodology to improve working relationships among the various functional organizations.

31, 70 Under the pending O&M contract scenario, this issue would become moot for most of the functional groups within ATM as most employees will be absorbed by the Contractor (Operations and Maintenance Teams) and a small administrative group will transition to PRITA (Legal, Finance, HR, etc.). In order to address any dysfunction in the relationships between ATM and PRITA, and any other transit organizations, this issue will be addressed through training during the transition of all transit modes under PRITA as part of the Law 123-2014 required reorganization of transit in Puerto Rico.

PRITA Although this becomes a responsibility of the O&M contractor, many of the same people will be working in the same positions for the contractor. It is incumbent on PRITA/ATM to include in their oversight plan, participation (by observation and feedback to the O&M contractor) in ensuring current issues are not carried over. Therefore, continuous observation/oversight/feedback is a recommended solution.




7

ATM It is clear that ATM management and its unions don’t always work effectively together. The PMOC recommends that improved relations with the unions become a management priority.

31, 70 Under the pending O&M contract scenario, this issue would become moot for trade union operational staff who transition to the contractor, retire through natural attrition, or could be offered early retirement (option under analysis). Enacting law for the P3 Authority allows flexibility for CBA changes as part of the P3 establishment. In the meantime, ATM has little ability to change the nature of its position with the unions, or conditions in CBA clauses, except for extraordinary compensations or clauses with economic impact (Law 66-2014 suspends any CBA negotiations while active). Other non-operational roles at PRITA may be filled by transferred union staff who would also bring their current CBAs with them (this is relevant to 8 job descriptions at PRITA).

P3 Although Puerto Rico Law apparently allows P3s certain flexibilities with union CBAs, the PMOC highly recommends that PRITA/ATM not depend on the O&M contractor to deal alone with any potential union issues. Use of the aforementioned IPT (Item 5, minus the USCG), plus appropriate PRITA/ATM oversight within the framework of the O&M contract may be required. At this time, it is uncertain if there will be continued union representation during the O&M contract; however, the PMOC recommends that PRITA/ATM closely monitor this item.

8

ATM Formalize a process for training, certifying and promoting mariners.

31, 70 This is required in the ferry O&M RFP. P3 PMOC agrees with the proposed mitigation plan, however, PRITA must develop a metric by which the contractor's compliance is measured. Please provide the metrics to the PMOC.




9

ATM Continue to report and deliver to the PMOC the operations data on performance measures included in Table 3 of this report. Achieve the performance goals and maintain performance above these goals.

31, 70 ATM and PRITA will continue to collect and submit this data to the PMOC using the forms agreed. The O&M RFP requires contractors to provide this data. The Technical Oversight Support RFP will also require the collection and evaluation of this data.

PRITA Provide data collected to FTA and the PMOC.

10

ATM Develop a plan for the future use of the water taxi consistent with FTA requirements and the remaining federal interest.

31, 70 ATM will develop a plan to modify La Decima into a support vessel; or install at Catano terminal a device that would allow ADA compliance.

ATM Provide a schedule for completion of this action item.

11

ATM Develop a plan for the eventual replacement of the two catamarans.

31, 70 Conway's 5-yr and 10-yr cash flow scenarios consider fleet replacement funding for replacement of Amelia and Covadonga.

ATM Provide the sections of the 5 and 10-year plans with FTA

12

ATM Continue to closely monitor and provide input to the P3 Authority’s procurement process. Ensure that the final procurement documents effectively protect federal assets and continue to allow PRITA/ATM to receive FTA grant support.

31, 70 DTOP and ATM will continue to do so. The RFP will be released by P3 Authority in February 2016 after incorporating changes requested by the PMOC/FTA, DTOP, and ATM.

ATM PMOC agrees with the proposed mitigation plan, but the PMOC strongly recommends that it continue to provide expert analysis and input during the entire RFPQ, evaluation, and award process.

13

ATM Continue to fully implement a formalized PM and maintenance management system.

31, 70 ATM will continue to do so, subject to the availability of funds locally. This will also be required in the ferry O&M plan.

ATM PMOC agrees with the proposed mitigation plan. However, this is an FTA eligible expense. This should not be subject to local funds availability.

14

ATM Provide the PMOC monthly updates of the matrix listing of all required certifications and permits for all vessels.

31, 70 ATM and PRITA will continue to do so. This will also be required in the ferry O&M plan.

ATM PMOC agrees with the proposed mitigation plan and will continue to monitor implementation.

15

ATM Report and deliver to the PMOC the maintenance data on performance measures included in Table 3 of this report, achieve the performance goals and maintain performance above these goals continuously.


ATM PMOC agrees with the proposed mitigation plan and will continue to monitor implementation.




16

ATM Continue to provide the necessary resources to meet federal and local regulatory requirements for safety and security.


ATM PMOC agrees with the proposed mitigation plan, however, PRITA must develop a metric by which the contractor's compliance is measured. Provide the metrics to the PMOC.

17

ATM Designate a person or persons within the organization as the point(s) of contact for the USCG for all potential safety and security issues: inspections, investigations, pollution, mass casualties, port security, etc. Have that/those individual(s) contact their USCG cohort in order to establish and maintain a professional relationship.

32, 71 ATM will formalize current contact persons: Auxiliary Executive Director for Operation and Service; PM Coordinators; and FSO as official liaisons for USCG. Under the revised PRITA organizational chart, maritime safety and security (FSO) will reside with the maritime operations group, and will be staffed through a combination of existing local staff and consultant resources procured through the Technical Oversight Support RFP.

ATM/PRITA PMOC agrees with the proposed mitigation plan and will continue to monitor implementation.

18

ATM Obtain technical assistance in the development of processes and procedures for oversight of operation and maintenance services.

32, 71 These processes and procedures will be developed as part of the services provided by the Technical Oversight Support RFP consultants. PRITA will involve the PMOC in review and comment on any draft processes and procedures developed by its oversight consultants prior to acceptance and implementation.

PRITA PMOC agrees with the proposed mitigation plan and will continue to monitor implementation.

19

ATM Develop and gain approval of a financial plan to match any new ferry construction plans, ongoing dry-docking and refit programs, and any shore-side improvement plans.

32, 71 ATM has created a financial plan for future capital investment that was included in the Conway Report. ATM and PRITA will involve the PMOC in future discussions, as well as its O&M service provider.

PRITA Provide the financial plan for future capital investment. Who will be the source of the investment, the Commonwealth or the O&M Contractor?




20

ATM Ensure full implementation of the recently adopted PRPA procurement acquisition regulations.

32, 71 ATM's Finance and Administration Area is currently adapting the 13 desk reference procedures provided by the FMOC, and supplemented by PRITA to meet local regulations, to ATM's current available resources. ATM's Finance and Administration Area is also working on adapting the P.R. Ports Authority's procurement manual for this same reason (pending its adoption, it is being followed by ATM). From an operational perspective, ATM could make use of the PMOC's technical assistance to collect and/or draft all other processes and procedures. With respect to collection of drawings for the vessels, ATM has already obtained copies that are locally available by USCG Sector San Juan and have quotes from the vessels' builders (except for M/V Caribeña - VT Halter).

ATM FTA will consider ATM’s request of assistance from the PMOC.

21

ATM Complete implementation of the automated inventory system, and its integration with the purchasing and financial systems.

32, 71 ATM and PRITA will continue to do so. The expected implementation date of the system for Phase III (Fajardo) will be complete within the next 6 months. Other locations have already been completed.

ATM PMOC agrees with the proposed mitigation plan. Progress is being made, but original deadlines are not being met.

22

ATM Develop formal training and certification criteria and procedures to meet future USCG and organic requirements.

32, 71 PRITA and ATM will require the relevant criteria and procedures be developed by consultants under the Technical Oversight Support RFP. This will also be required in the ferry O&M plan. In both cases, PRITA and ATM will work with the PMOC and the USCG to ensure the development and implementation of appropriate criteria for training.

PRITA PMOC agrees with the proposed mitigation plan. This will also be an area that the PRITA/Contractor/USCG IPT can greatly help.




23

ATM Execute the plans to automate the reservation and fare purchasing systems allowing ATM to more accurately capture ridership and revenue data.

32, 71 ATM has a project undergoing to update the reservation and fare purchasing system at the Island service. ATM is attempting to extend the current ticketing system (with modifications to the software) to Metro. The timeframe for this project is approximately 6 months. Funds are still not fully available to complete this project (shortfall is approximately $250,000). ATM is interested in the discussion of this shortfall through existing FTA grants. This is an interim step prior to a larger CUBIC implementation which will likely take more than two years to implement.

ATM/PRITA PMOC agrees with the proposed mitigation plan, however this project being addressed in conjunction with the other modes. The PMOC will continue to monitor implementation.

24

ATM Update the FMP, and develop a Safety Management System for the fleet.

32, 71 PRITA and ATM will require the relevant criteria and procedures be update or developed by consultants under the Technical Oversight Support RFP. This will also be required in the ferry O&M plan. In both cases, PRITA and ATM will work with the PMOC and the USCG to ensure the development and implementation of the FMP and Safety Management System.

PRITA PMOC agrees with the proposed mitigation plan, however, this will be an expensive endeavor if given to the contractor to accomplish.




25

AMA AMA should consider the benefits that career employees bring to the core positions within the agency.

46, 72 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of all transit modes. This recommendation will be addressed in a twofold approach; first, technical oversight consultants will be hired by PRITA through an RFP to immediately address any current gaps in technical capacity; second, these consultants will then train permanent replacements in the form of career local employees to perform these key oversight and management roles.

PRITA PMOC agrees with the proposed mitigation plan, however the qualifications, education and skill sets of the technical oversight consultants that will be hired through PRITA is critical, ensuring they possess the education and qualifications to address the gaps in technical capacity and skill sets needed to train the permanent replacements. Training curriculum should be developed, revised and updated as needed to ensure there is a current and robust training program in place. Provide the proposed qualifications and experience for these consultants.

26

AMA The PMOC review found that while some current positions are filled by long term experienced personnel, others have backgrounds that do not necessarily fit their current responsibilities.

46, 72 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of all transit modes. This recommendation will be addressed in a twofold approach; first, technical oversight consultants will be hired by PRITA through an RFP to immediately address any current gaps in technical capacity; second, these consultants will then train permanent replacements in the form of career local employees to perform these key oversight and management roles. Additionally, PRITA expects to issue an RFP for a bus O&M contract this year which will require all key position hires to demonstrate appropriate experience and licensing for operational roles.

PRITA / P3A PMOC agrees with the proposed mitigation plan, however, it was determined and noted in the TC&C Report, that several of the current staff at AMA have the experience and tenure and are currently performing well in their respective areas. The PMOC cautions against replacing staff that are already doing the job. Provide revised organization chart for verification. Provide a timeline (month/year) to complete the first of the two-fold approach. Also, when available, provide the draft RFP documents for the bus O&M contract.




27

AMA AMA should conduct a comprehensive review of its core positions to determine what level of expertise and experience is needed to properly serve the Agency. Career track positions would also help to establish qualified persons to meet specific functional job descriptions today and in the future.


PRITA PMOC agrees and recommends that AMA updates and develop a complete set of core job descriptions describing the core function of each career position including related educational requirements and minimum number of years of experience needed. Provide revised organization chart for verification. Provide a timeline (month/year) to complete the first of the two-fold approach. Also, when available provide the draft RFP documents for the bus O&M contract.

28

AMA AMA should adequately address all of the functions as identified in Table 7 - Current AMA Functions.

46, 72 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of all transit modes. This recommendation will be addressed in a twofold approach; first, technical oversight consultants will be hired by PRITA through an RFP to immediately address any current gaps in technical capacity; second, these consultants will then train permanent replacements in the form of career local employees to perform these key oversight and management roles.

PRITA PMOC agrees with proposed mitigation plan. It is important for the AMA organization to capture key functions that support the role and responsibility of the organization. Provide revised organization chart for verification. Provide a timeline (month/year) to complete the first of the two-fold approach.




29

AMA AMA should update the Bus Fleet Management Plan and financial systems; and develop a Safety and Security Plan.

46, 72 In addition to AMA's continued current efforts, AMA and PRITA will address this action item via technical oversight consultants hired by PRITA and through an O&M RFP for bus services under PRITA this year. AMA has an approved Safety and Security Plan since 2014.

AMA/PRITA The submission of an updated BFMP to the FTA is critical. The BFMP provides the roadmap for fleet management, procurement planning and funding priorities and should be developed/ updated and submitted ASAP.

30

AMA AMA should implement a Daily Fleet Status Report, and conduct a senior management level review routinely. Included in the report should be pull-outs, vehicles out of service by category, in-service failures (miles between road call or similar), and status of repairs/availability of parts, etc. Many performance standards are available from other US bus transit agencies.

46, 72 AMA has a Daily Fleet Status Report that partially meets this information requirement. The Vehicle Maintenance data system needs to be updated to improve data entry quality and reporting capabilities. In addition to AMA's continued current efforts, AMA and PRITA will address this action item via technical oversight consultants hired by PRITA and through an O&M RFP for bus services under PRITA this year, and will include performance metrics success as part of the RFP requirements for contractor compensation (which will be monitored and overseen by the technical oversight consultants at PRITA).

AMA/PRITA AMA should revise its Daily Fleet Status report to meet the requirements recommended by the PMOC using other transit agencies daily report examples as a template.




31

AMA AMA should implement a Monthly Progress Status Report for submission to the FTA prior to the regularly scheduled monthly meetings which includes graphs of daily performance measures (cost per vehicle mile, or similar standards as tracked in the National Transportation Database) for both fixed-route and paratransit service, tabulation and explanation of out-of-service vehicles, status of inactive fleet (progress for retirement), planned performance for the next month and the balance of the fiscal year (goals/standard to be achieved) and actual performance versus the plan.

46, 72 In addition to AMA's continued current efforts, AMA and PRITA will address this action item via technical oversight consultants hired by PRITA and through an O&M RFP for bus services under PRITA this year, and will include performance metrics success as part of the RFP requirements for contractor compensation (which will be monitored and overseen by the technical oversight consultants at PRITA).

AMA/PRITA PMOC agrees with mitigation plan. Provide relevant documents to verify progress.

32

AMA For AMA to improve its operations, it should establish performance standards, communicate them to employees and actively monitor those standards. There should also be more cross-training of staff.


PRITA PMOC agrees with the mitigation plan and also suggests incorporating shop talks across all maintenance shifts and posting/sharing of results with other departments.

33

AMA AMA should adopt a “Beat the Target” mentality on performance measures. This mentality is extremely important for the maintenance activities, but can be applied to the transportation operators and support departments as well. Charter those performing the work to meet the performance targets and communicate the results on a daily basis.


AMA PMOC agrees with the mitigation plan but in the interim AMA staff should start posting daily results immediately.




34

AMA AMA should adopt a “Customer First” mentality for the entire organization. Communicate a customer chain from each employees function through to the ultimate customer – the bus or paratransit rider.

46, 72 AMA and PRITA will address this action item via the creation of customer focused performance metrics by the technical oversight consultants hired by PRITA and through an O&M RFP for bus services under PRITA this year, and will include customer focused performance metrics success as part of the RFP requirements for contractor compensation (which will be monitored and overseen by the technical oversight consultants at PRITA).

PRITA PMOC agrees with mitigation plan and suggests the creation of Citizen Advisory Committees for fixed route and paratransit services. Committees are comprised of riders who use AMA service, serve a term (usually 12 months) meet monthly or quarterly, have an elected chair (voted on by the committee members) and have AMA staff attend.

35

AMA Re-train staff who are not performing adequately to gain the skills to achieve performance standards.


PRITA PMOC agrees and notes how this ties in with Item #28 and the identification of the AMA functions. Some areas may require re-certification standards and/or the flexibility to transfer staff to other areas or disciplines in their skills and training if not meeting performance standards.




36

AMA In order to better define and communicate necessary actions by all employees, adopt the Four P’s – Policy, Plan, Procedure, and Process. Policy as set by top management; Plan as a set of actions to implement the policy; Procedure to further define specific actions in a step by step of how to do it; Process as the actual work performed by carrying out and/or interpreting the procedure. This method is particularly effective in doing operations and maintenance plans and SOPs or can be used to assist in creating job descriptions and training programs.

46, 73 This methodology will be a requirement for the policies, procedures, and processes created and monitored by the technical oversight consultants to be hired by PRITA for oversight of bus operations and will be included in the Technical Oversight Support RFP.

PRITA PMOC agrees with mitigation plan. Provide the policies, procedures and processes when they are available.

37

AMA The PMOC recommends that the newly defined core functional positions as illustrated in Figure 4 remain within AMA as they are envisioned as essential to the successful operation of transit bus service in San Juan.

47, 73 These positions are included in the revised PRITA Organizational Chart and will be filled through the Technical Oversight Support RFP and its consultants. This consultant team will then backfill these positions for bus operations with local career employees over time.

PRITA PMOC agrees so long as the positions are backfilled with qualified local career employees prior to the end date of the Technical Oversight Support consultants contract. Provide revised organization chart for verification. Provide a timeline (month/year) to complete the first of the two-fold approach.

38

ATI The PMOC recommends that in the interim and within the next six months, ATI/PRHTA retain an on-call General Management, Architecture and Engineering Consultant (GMAEC) to provide technical support for the oversight of the O&M contractor, and engineering support for capital projects.

6, 73-74 The scope of the GMAEC contract will be filled by ATI/PRHTA within the 6 months timeline required.

ATI/PRHTA PMOC agrees with mitigation plan however the recommendation will remain open until contract is awarded and the GMEAC is given NTP.




39

ATI ATI/PRHTA develop a plan of action with milestones or a timetable that lays out ATI’s strategy toward effectively building and implementing an organization with the technical capacity and capability to oversee TU operations in house inclusive of external technical consultants.

6, 60, 74 This timetable/list of milestones will be part of the requirements for the GMAEC contract filled by ATI/PRHTA within the 6 months timeline required.

ATI/PRHTA The reply is insufficient. ATI/PRITA should draft a plan of action and timetable/milestones and provide it to the PMOC to review and comment.

40

ATI The ATI organization would benefit if all maintenance activities are under the direction of one manager, with support staff directly responsible for oversight in the field. Additionally, ATI needs to reestablish oversight of those areas that are no longer being monitored, including train operations, QA/QC auditing and structural integrity inspections.

6, 60, 74 These oversight roles will be part of the requirements for the GMAEC contract filled by ATI/PRHTA within the 6 months timeline required.

ATI/PRHTA The response did not address the recommended organizational changes within ATI however, the February 2016 organizational chart indicates that there will be a single manager for each transportation mode, including rail.

41

ATI ATI needs to provide proper training and tools needed for staff to perform their field inspections effectively and should institute weekly meetings with the O&M operator to discuss issues, concerns and upcoming activities. Minutes and action items should be developed as a result of these meetings, identifying responsible parties and dates for completion.

6, 60, 74 These training and tools activities will be part of the requirements for the GMAEC contract filled by ATI/PRHTA within the 6 months timeline required.

ATI/PRHTA The reply is insufficient. There are a number of items in the recommendation that should be addressed immediately by ATI, such as instituting weekly meetings with the O&M operator and preparing minutes and action items for the weekly meetings. The GMEAC can provide additional support for that effort after NTP.

42

ATI Revise the ATI position descriptions to correctly describe the specific duties and responsibilities of the positions, including position qualifications and desired experience. Include in the position descriptions that staff are required to participate in rail industry technical peer groups and to acquire knowledge of industry developments in their specialized areas.

60, 74 ATI/PRHTA will seek in the short term to address this issues by providing FTA with the appropriate scope of position qualifications for key positions.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until staffing plan documentation is provided to the FTA.




43

ATI Develop and execute a staffing plan to fill the vacancies in its organization; consider hiring qualified staff with prior rail transit management experience.

60, 74 ATI/PRHTA will seek in the short term to address this staffing plan gap by providing FTA with a plan, scoped to include appropriate staff experience requirements.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until staffing plan documentation is provided to the FTA.

44

ATI Develop peer contacts at other rail properties. 60, 74 ATI/PRHTA will work with the PMOC to develop contacts at other rail properties. ATI/PRHTA will also utilize APTA forum opportunities to improve staff contacts at other rail properties.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until plan is implemented and contacts are established.

45

ATI Provide notice to underperforming employees that they need to improve their job performance or be replaced. Provide those employees with the opportunity to attend training and mentoring programs to improve their performance.

60, 74 ATI/PRHTA will provide this guidance to employees and identify further training opportunities through APTA and other forums.

ATI/PRHTA The reply is insufficient. ATI/PRITA should provide the FTA with an employee performance monitoring plan and advise of actions taken regarding underperforming employees.

46

ATI Provide a personnel retention plan. Consider combining positions and offering a higher pay structure to qualified staff.

60, 74 ATI/PRHTA will provide FTA with a personnel retention plan, scoped to include compensations. This is also limited potentially by local requirements, laws and labor classifications.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until staff retention plan documentation is provided to the FTA.

47

ATI With the assistance of the PMOC, develop a list of potential training opportunities for staff; FTA has advised that federal funds are available for staff training.

60, 74 ATI/PRHTA will provide this guidance to employees and identify further training opportunities through APTA and other forums, and pursue further discussions with the PMOC.

ATI/PRHTA ATI/PRHTA should determine the employees' training needs based on performance appraisals. ATI/PRHTA to provide milestones for monitoring employee training progress.

48

ATI Develop and implement a program for overseeing train operations, including dispatching, and train crew performance.

6, 61, 75 The scope of the GMAEC contract will address this program requirement. This will be addressed by ATI/PRHTA.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until oversight program is in place.




49

ATI Resolve any outstanding items related to the Siemens warrantee agreement.

61, 75 We have no problems with the guarantees. ATI's position is that if operators use a replacement part and not an original piece, the warranty would be void. Cannibalism is performed by the operator as it does not want to assume the cost of the piece, as it is too expensive to pay for new parts. The TU is unique and therefore only the parts are manufactured by Siemens. In order to produce the parts that make faults, the manufacturer needs to produce for other system and produce only for ours. This makes the parts more expensive. The Authority sent letters to the operator to cease this practice, but the operator continues.

ATI/PRHTA The reply is insufficient. ATI/PRHTA needs to take action to immediately address the problem. Vehicle cannibalism is unacceptable. If the O&M contractor will not order the correct parts, ATI/PHRTA should directly order the parts and deduct the costs from the O&M contractor's compensation.

50

ATI Establish a plan to restore the four cannibalized vehicles to full operating service.

61, 75 ATI will : 1. Create spare part inventory for preventive and corrective maintenance activities. 2. Review Maintenance Plan in order to assure consistency with new O&M Contract.

ATI/PRHTA The reply is insufficient. ATI actions relate to preventing cannibalistic-actions in the future contract. It does not include actions to remedy the current condition ASAP. The PMOC continues to request a timeline for restoring the four cannibalized vehicles to full operating service.

51

ATI Establish a plan to perform preventive maintenance work on the elevators and escalators.

61, 75 Currently, Schindler has a contract with ACI to provide preventive and corrective maintenance for escalators and elevators. In response to comments in page 58 of 212 in part B.2 Operations and Maintenance. Evidence will be submitted as requested. This contract is all inclusive.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until documentation is provided.

52

ATI Develop a near term and long term capital plan that is required to keep the TU system in a state of good repair.

61, 75 ATI/PRHTA will develop and Implement a 5-yr Capital Improvement Plan. ATI/PRHTA will review Conway Model for current assumptions on capital plan.

ATI/PRHTA The 5 year plan is a long term plan. ATI/PRHTA needs to develop a plan for immediate action items to remedy existing problems.




53

ATI Establish a stronger safety oversight and review process.

61, 75 In addition to ATI's current efforts, including the placement of Carlos Sanabria as the safety officer at ATI, the GMAEC RFP will contain requirements for the consultants to develop safety and oversight and review processes for rail. The agency shall develop a Master Safety Plan for TU Operations. (The O&M Contractor shall provide its own Safety Plan based on this). The Master Safety Plan shall include, but should not be limited to, Transportation Safety, Vehicle Safety, Physical Plan and Maintenance Safety, Consistent training to staff, emergency responses and oversight and analysis of Tren Urbano hired police and security programs.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until plan is completed.

54

ATI Reinstitute a QA/QC program. 6, 61, 75 ATI/PRHTA will establish a QA/QC program within the scope of the GMAEC RFP and Contract.

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until QA/QC plan is in place.

55

ATI Implement a structural integrity program for the guideway, tunnels and structures that is in accordance with industry standards. Ensure that ATI managers are aware of all structural integrity reports and issues.

61, 75 Currently, the report is now responsibility of PRHTA's Bridge Inspection Division. This will be addressed on a go forward basis through the scope of the GMAEC RFP and contract.

ATI/PRHTA Process for ATI managers to receive and review existing structural integrity reports not described.

56

ATI Review and update all management plans, including the SOPs, incorporating existing procedures and newly developed procedures.

6, 61, 75 The generation of management plans will be the result of the new O&M contractor subject to review and approval by the oversight team (GMAEC contractor and ATI/PRHTA).

ATI/PRHTA PMOC agrees with mitigation plan, however the recommendation will remain open until updated management plans are prepared.




57

PRITA PRITA should consider the benefits that career employees bring to the core positions within the agency.

7, 66, 75 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts).

PRITA Please provide the latest organization chart for verification.

58

PRITA Consider career positions for the key PRITA staff as shown in Figure 8 to ensure that the agency continues to operate effectively during political transitions and for the retention of knowledge.

66, 76 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts).

PRITA Please provide the latest organization chart for verification.

59

PRITA PRITA research prior history when ATM, AMA and ATI were under one umbrella and use the information to develop a process to ensure proper accountability of ferry, bus and train funds.

66, 76 ATI-HTA was initially created as an adjunct office of the HTA Executive Director around 2003. ATI has never functioned as an umbrella organization for AMA or ATM. Around 2006-07, some ATI employees were appointed in key "trust" positions in AMA (holding both responsibilities), other ATI employees were simply located in AMA areas, but no funding or formal organization integration occurred between AMA and ATI from that effort that lasted about two years.

N/A No comment.




60

PRITA The PMOC recommends that PRITA develop a General Manager position requiring at least 10 years of prior transit experience. This position needs to be a “career” position in lieu of a “trusted” position.

76 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts). The updated org chart includes separate managers for the respective transit services and a Director of Transit Operations that has the responsibility of supervising the different transit service managers. In this organization structure, the PRITA Executive Director is positioned as the Chief Executive Officer in charge of implementing public policy and the overall administration of the public corporation. The General Manager, the Director of Transit Operations, and the separate Intermodal Transit Managers the transit director, all career employees, will be in charge of the day-to-day operations. Some of these positions will be filled through the Technical Oversight Support RFP and its consultants. This consultant team will then backfill these positions with local career employees over time.

PRITA Provide the proposed qualifications and experience for these positions.

61

PRITA The PMOC recommends that a QA manager and properly trained staff should be included in the PRITA organization to regularly audit ferry, bus, and train operations and maintenance.

7, 67, 76 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts).

PRITA Provide the latest organization chart for verification. Provide the proposed qualifications and experience for this position.




62

PRITA PRITA indicates it is an “oversight agency”, but the number of staff in the organization seems high for the operations that are being provided compared to similar operations within the United States. The PMOC recommends that PRITA streamline the agency, reconsidering the number of staff being proposed, and consider the benefits of career positions.

7, 67, 76 Not clear which evaluation criteria was used by the PMOC to conclude that the 143 employees for PRITA is a large number from the information provided in the grantee solicitation. The total of 143 employees indicated as part of the solicitation were based on a different scenario in which PRITA was going to be in charge of direct operations for buses and ferries services (AMA and ATM, respectively). The new PRITA organization sustained changes after the submittal of the grantee application in July 2015. The update of the PRITA solicitation, as an oversight organization, has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts).

PRITA Provide the latest organization chart for verification. Provide the manpower loading charts.

63

PRITA PRITA should upgrade their computer systems and train staff to work with the technology.

67, 76 PRITA has already installed new software and equipment at its offices with the necessary IT systems and technology to be ready to support managerial and financial operations for AMA and ATM. Staff training is pending approval to implement and consolidate financial and accounting procedures using accepted federal procedures. Nevertheless, PRITA will review any additional required IT needs that are identified as part of the transition and implementation period.

PRITA Please provide supporting documentation of upgrades and required training.




64

PRITA PRITA should expand their management capacity and capability for all the modes, ensuring qualified staff for the oversight of all three transit modes.

7, 67, 76 This recommendation has been incorporated into the revised PRITA Organizational Chart for the management and oversight of ferry, bus and rail services (including the pending, planned and current O&M Contracts) and will also be addressed through the staffing provided by the Technical Oversight Support RFP.

PRITA Provide the latest organization chart for verification. Provide the proposed qualifications and experience for these consultants.

65

PRITA PRITA should have its own Title VI officer to monitor the various compliance items of the O&M contracts for ATM and AMA, as well as the future ATI organization.

7, 76 This recommendation has been incorporated into the revised PRITA Organizational Chart. This position will be addressed through a permanent hire, though current legal advisor to PRITA, Jose Montalvo, has extensive experience as a government legal disability advocate.

PRITA Provide the latest organization chart for verification. Provide the proposed qualifications and experience for this position.

66

PRITA PRITA needs to confirm how O&M activities will be combined for the buses operated by AMA and First Transit.

67, 76 The bus reorganization plan recently implemented considered the combined services provided by both AMA and First Transit. PRITA is requesting quarterly statistical data from all transit modes to evaluate potential service needs and updates. The issue of combining the O&M activities of the two bus services in one is part of the scope of the planned O&M contract for bus service procurement.

PRITA / P3A Provide the draft RFP documents for the bus O&M contract.




67

PRITA Provide the PMOC with all SOPs and PM procedures for all modes that PRITA will oversee.

67, 76 These oversight related activities are included in the revised PRITA Organizational Chart and will be filled through the Technical Oversight Support RFP and its consultants. This consultant team will then backfill these positions for operations with local career employees over time. The generation of draft plans is also the result of the new O&M contractors for each mode (TBD for bus operations) subject to review and approval by the oversight team (contractor and PRITA).

PRITA Provide/submit supporting documentation for all SOPs and PM procedures.

68

PRITA Demonstrate the implementation of a financial system in accordance with the FMOC findings and provide all necessary hardware, software and adequately trained staff.

8, 67, 76 PRITA has already approved the 13 FMOC financial procedures. The financial system is already installed and ready. The next phase is the training of staff at PRITA that implement the approved procedures, pending approval.

PRITA Provide supporting documentation that financial systems are installed and tested. Provide training schedule, and an overall completion date.

69

PRITA Demonstrate the implementation and sustainment of the FTA accepted procurement processes and procedures currently in use by PRPA.

67, 76 The PRITA board has approved the same procurement plan for use by PRITA and all relevant modes. The Technical Oversight RFP will be issued under the guidelines of the PRPA procurement manual (now the PRITA procurement manual) in order to demonstrate implementation. Sustainment will be the result of on-going use and annual audit results.

PRITA Provide supporting documentation to demonstrate the procurement processes and procedures are implemented.

Documents

VI. SUMMARY FINDINGS AND RECOMMENDATIONS status planes... · VI. SUMMARY FINDINGS AND RECOMMENDATIONS The following is a summary of the PMOC’s findings and recommendations for the