This memo outlines a proposed amendment to the 2023 Long Range Transportation Plan (LRTP) and the MPO Planning Boundary in response to findings from a 2024 FHWA/MDT review. While the review found the Billings MPO to be largely compliant, it required two technical updates: redesigning the LRTP project list and updating the MPO’s urban planning boundary to reflect 2020 Census data. The City contracted with Kittelson & Associates in March 2025 to complete these updates, which included a project list audit, boundary analysis, LRTP modifications, and public outreach. The amendment improves clarity, ensures compliance with federal and state requirements, helps protect and potentially expand access to federal transportation funding, and better positions staff for the next LRTP update in 2028.

The City Council received a presentation from MPO staff on January 20, 2026. The Technical Advisory Committee (TAC) reviewed the amendment on December 11, 2025, and is recommending approval by the Planning Board, City Council, and County Commission. The City/County Planning Board received a presentation and held a public hearing on January 13, 2026 at which no public testimony was provided. The City/County Planning Board received a presentation and held a public hearing on January 13, 2026 at which no public testimony was provided. The Board of County Commissioners heard a presentation at its Discussion Session on January 22 and is scheduled to take action on the amendments at its meeting on February 4. The Planning Board and the Board of County Commissioners are both in support of the LRTP amendments. Staff is recommending the City Council send a recommendation of approval to the Policy Coordinating Committee.

The Federal Highway Administration (FHWA) and the Montana Department of Transportation (MDT) conducted a routine review in 2024 of the Billings Metropolitan Planning Organization (MPO). The review was very positive overall as to the operations and compliance of the MPO. The report following the review stated: "The result of the review is a finding that the Billings metropolitan planning process substantially complies with the regulations under Subpart C -- Metropolitan Transportation Planning and Programming -- 23 CFR § 450 and related FHWA/FTA guidance."

However, there were several findings of the review that the MPO must address. Two findings focused on technical elements of the Billings Long Range Transportation Plan adopted in 2023. The findings specifically called for redesigning the project list in the 2023 Long Range Transportation Plan (LRTP) and updating the MPO's urban planning boundary to align with 2020 Census data. The FHWA did not express concerns over the project list information when it reviewed the plan for adoption in 2023. It was not until the review in 2024 that the agency brought up the issue and so the MPO is following the review findings to make sure the MPO and LRTP are in conformance.

Completion of these findings ensures compliance with federal and state guidelines while improving project transparency and usability. Amendment of the Urban Planning Boundary also may increase the MPO's access to transportation funding based on the additional area that may be included.

Staff will also address these review elements in preparation of the next Long Range Transportation Plan (LRTP) update, which is required every five years and scheduled for completion in 2028. Completing these technical updates now will better position MPO staff to conduct most of the LRTP update in-house, relying on only limited external technical support.

In March 2025, the City Council approved the Consulting Contract with Kittelson & Associates to complete the scope of this project. The scope of work for this specific set of technical findings — redesigning the project list in the 2023 Long Range Transportation Plan (LRTP) and updating the MPO's urban planning boundary — includes:

Project List Audit
 Review all project entries for accurate descriptions, timelines, costs, and funding sources.
 Identify discrepancies between listed projects and current funding allocations.
 Work with MPO, City and County staff, and MDT to verify project data.
 Provide a summary report with findings and recommendations for corrections.

Redesign of Project List
 Develop a revised project list with clearer descriptions and funding alignment.
 Propose a standardized format for readability and ease of use.
 Ensure compliance with FHWA and MDT guidelines.
 Incorporate feedback from MPO staff and stakeholders.

Urban Planning Boundary Update
 Analyze 2020 Census data and demographic shifts affecting the boundary.
 Create updated GIS maps and support documentation.
 Integrate the new boundary into the 2023 LRTP.

LRTP Modification
 Update the LRTP to reflect the revised project list and urban planning boundary.
 Ensure the modification aligns with FHWA and MDT requirements.
 Conduct public outreach and document community feedback. 

Approving the 2023 LRTP project list update and MPO PL boundary amendment helps maintain federal funding eligibility by ensuring the financial plan is fiscally constrained and compliant with federal transportation planning requirements.

Updating the boundary to match the current urbanized area also protects access to key federal programs, such as Surface Transportation Grant, Transportation Alternative Program, and PL funds, and reduces the risk of misallocated or lost funding.

This action does not approve specific projects or funds at the project level to move a project forward. 

City Council May:

· Recommend the PCC approve the LRTP and MPO Boundary Amendment as presented and have the City Council PCC representative to carry this recommendation to the February 17, 2026, PCC meeting.

· Make amendments to the LRTP and MPO Boundary Amendment and forward those amendments to the PCC for consideration and have the City Council PCC representative carry this recommendation to the February 17, 2026, PCC meeting.

· Recommend denial of the LRTP and MPO Boundary Amendment to PCC and have the City Council PCC representative carry this recommendation to the February 17, 2026, PCC meeting. Rejection of the Amendment would conflict with the operations of the Billings MPO and could lead to negative impacts on future Federal funding. This would affect Planning staff, resources, and future transportation planning programs.