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American Rescue Plan Act (ARPA) Funding for Complete Streets and Trails Projects

ARPA funding may be used for projects that address current COVID impacts and longstanding challenges exacerbated by the pandemic. WGI’s Lisa Nisenson highlights some ways that Complete Street and trail projects may potentially qualify for funding.
American Rescue Plan Complete Streets ARPA

by Lisa Nisenson, VP, New Mobility and Connected Communities

Communities around the country are developing strategies on how to win and invest American Rescue Plan Act (ARPA) funding. This blog post examines how to position Complete Streets and trails projects for ARPA funding.

What is the ARPA?

In a nutshell, ARPA provides $350 billion for state, local, territorial, and tribal governments to address COVID-related economic impact through the State and Local Fiscal Recovery Fund. On May 21, 2021, the U.S. Department of Revenue issued an interim final rule (referred to as interim rule hereafter) establishing funding criteria. Please see our July 20, 2021 blog post for additional details.

Funds can be used for projects that fall under the following use categories, and address both current COVID-related impacts and longstanding challenges exacerbated by the pandemic:

  • Public health expenditures
  • Addressing negative economic impacts
  • Replacing lost public sector revenue
  • Funding essential worker pay
  • Building infrastructure including water, wastewater, stormwater, transportation, and broadband
  • Funding elementary and secondary school emergency relief

The interim rule allows for creativity in crafting locally relevant project lists and services. The interim rule does, however, reference example projects that address COVID-related impacts and needs. This post highlights specific passages and references that support use of ARPA funding for trails and Complete Street projects. Some references are explicit, while others require “connecting the dots” between Complete Streets benefits and COVID recovery.

Why Complete Streets and Trails for COVID Recovery?

For two decades, researchers have amassed a robust body of research demonstrating the benefits of Complete Streets and trails. WGI is a silver partner in the Complete Streets Coalition (a project within Smart Growth America), a group of researchers, advocates, and practitioners advancing best practices for designing multi-modal streets.

  • 48% of all car trips are less than three miles in length, with about twenty percent being shorter than one mile (source: INRIX, 2019)
  • Heavy traffic and lack of separated paths or trails were the most frequently identified barriers to bicycling more (source: Journal of Transport & Health)
  • Greenhouse gas (GHG) emissions from transportation are the single largest source of greenhouse gases in the U.S., accounting for about 29% of total GHG emissions (source: EPA)
  • In a typical community, 20- 40% of residents cannot, should not, or prefer not to drive for most trips, and so benefit from multimodal planning that responds to those demands (source: Victoria Transportation Policy Institute)
  • In areas where over 20 percent of households are below the federal poverty line, the pedestrian death rate is more than 80 percent higher than the U.S. average (source: Smart Growth America)
Complete Streets
Working with the city of West Palm Beach FL, WGI designed a Complete Street integrating bioswales and canopy trees along Banyan Boulevard.

There are three areas where Complete Streets and trail projects may align with ARPA funding criteria: public health, addressing economic impacts, and infrastructure.

Public Health

The public health impacts experienced due to COVID are both direct and indirect. ARPA funding eligibility will rest on clearly articulated needs and/or negative impacts of COVID. Successful project applications will identify how the project addresses the identified need or impact.

ARPA Public Health Complete Streets

Economic Impacts

Eligible projects must be designed to address an identified economic harm resulting from or exacerbated by COVID. Responses must be related and reasonably proportional to the extent and type of harm experienced.

ARPA Economic Impacts Complete Streets


Infrastructure within ARPA is defined largely as (1) broadband and (2) water projects that would also be eligible for funding under the Clean Water State Revolving Fund (CWSRF) or the Drinking Water State Revolving Fund (DWSRF).

The interim rule notes that general infrastructure projects typically would not be included unless the project responds to a specific pandemic public health need or a specific negative economic impact. That said, the interim rule does note eligibility for certain infrastructure maintenance projects considered a government service (maintenance or pay-go funded building of infrastructure including roads) and green streets.

ARPA Infrastructure Complete Streets

Complete Streets
Mobility technologies are increasing the number of modes and travel choices, spurring increased demand for street, curb, and sidewalk space. WGI has created a new service line, Complete Streets+, to help cities plan and manage bustling rights of way.

Making Preparations

As entities assemble ideas for using ARPA funds for Complete Streets and trails, the following points are important:

  1. Funds are being released in two stages for states, cities and counties: half of the funds were made available in May 2021, with the second half to be released in May 2022. Funds needs to be obligated by 2024 and projects completed by 2026.
  2. Funding is one time in two phases. If you are considering new programs and positions, determine how to sustain these programs once the APRA funds have been expended.
  3. ARPA emphasizes the pandemic’s disproportionate impacts on low-income communities, people of color, and Tribal communities in two areas: (1) higher rates of infection and illness, and (2) higher impacts where COVID exacerbated structural inequities and underinvestment. This will require new stakeholders who have the ear – and the voice – of neighborhoods often left out of infrastructure planning.
  4. Government officials have not yet released final details on reporting requirements; however, your team should include colleagues from financial departments who will be responsible for accounting, audits and reporting. Also think about KPIs (key performance indicators) you will track to describe project success. Because the interim rule emphasizes the importance of climate, resilience, and equity, be prepared to include these alongside traditional transportation and infrastructure metrics.
  5. The interim rule notes that additional guidance is still forthcoming on several areas of funding, project selection, and reporting. This post offers insights on guidance to date of publication; new guidance may change or refine project eligibility, so be sure to contact us to speak with someone about the latest guidance.

How WGI Can Help

WGI is working with communities across the country on complete streets and trails. For ARPA funding, we’ve been working on ways to “connect the dots” between ARPA goals and Complete Streets and trails projects. Moreover, we look for project design that meets multiple goals at once, including the mobility, public heath, economic development, and resilience goals listed in the interim rule.

To learn more, contact Lisa Nisenson at lisa.nisenson@wginc.com if you would like to leverage ARPA funds for local Complete Streets, trails, and green street projects. We can provide tips on getting started, including making the case, how to stage projects, engage new stakeholders, and set Key Performance Indicators (KPIs). We can also provide example project proposals from around the country.

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