act 44 performance standards regulation development april 24, 2009 bob kaiser - michael baker jr.,...

Act 44 Performance Standards Act 44 Performance Standards Regulation DevelopmentRegulation Development

April 24, 2009April 24, 2009 Bob Kaiser - Michael Baker Jr., Inc.

Walt Cherwony - Gannett Fleming, Inc.

Anna Lynn Smith, Parsons Brinckerhoff

In association with:

Draft - Discussion Purposes Only

Draft – Discussion Only2

Discussion Outline

1. Overview of Development Process

2. Progress to Datea. Researchb. Data and Definitionsc. Peer Selection Process d. Performance Measures Selectione. Overall Processf. Continuous Improvementg. Estimated Timeline of Events

(preliminary)

3. Next Steps4. Questions / Discussion


Overview

Research & Development Tasks 1. Background2. Legal Req., Research Materials,

Gap I.D. 3. Peer Selection Process4. Performance Measure

Development Process5. Data and Definitions6. Performance Review Process 7. Potential Impacts8. Consultation


Overview (continued)

Schedule

Jan March May July

1 Background

PA Bulletin

2 Research

5 Data, Definitions

3 Peer Selection

4 Performance Measures

6 Devel. Overall Process

7 Impacts

8 Consultation



3-18-09

Draft OverviewPennsylvania Public Transportation Agency Performance Review Process

Review Cycle Initiated

System Notification and

Kick-Off

Field Work/Data Acquisition &

Analysis

Draft Performance

Report

Review Report with Transit

Agency/Finalize

Follow-up, Corrective Action, and Monitoring

DOT Planning and Preparation.

DOT-Award Recipient Consultation.

Draft Report of Findings v. Prior-Established Performance

Standards. Identify Poor & Exemplary Performance.

DOT-Award Recipient Consultation. Review Results, Discuss Action Plan, Identify Action Plan Elements. DOT-

Grant Recipient Meeting.

Document Exemplary Performance. Track

Corrective Action Plan Implementation. Report

Results.

Peer selection, Data Acquisition & Analysis, Draft

Initial Performance Standards


# PPTA Recommendation for Topics Studied To-DateCurrently Planned

Under Study

1 Focus on Continuous Improvement √

2 Consultation w/ Subject Agency √

3 Peers Individual to Subject Agency / Mode √

4 Number of Peers: 8-12, Possible Exceptions √

5 Peer Selection Characteristics / Criteria √

6 Peers Include PA Systems As Possible

7 Act 44 Perf. Standards - Four (4) √

8 Additional Meas. Per Subj. Agency Needs / Priorities √

9 Final Additional Measures

10 NTD Data (as available) √

11 dotGrant Data (NTD not avail.) √

12 Other Data Sources √

13 Training for Grantees √

14 5 Year Interval √

15 Regular Consultations during Review √

16 Special Considerations / Circumstances Beyond Control √

17 Document Exceptional Performance & Best Practices √

18 Straightforward Performance Standard Calculation √

19 2 Yr. Waiver to Gain Compliance w/ Standard √

20 Compliance Metric √

21 Additional Waiver Time to Gain Compliance w/ Standard √

22 Funding Sanctions Triggers √

PPTA Committee Recommendations



Systems Encompassed Urban and Rural Public Transit

Systems

Modes Encompassed Fixed Route Public

Transportation Modes Evaluation by Mode

Not being considered at this time: ADA paratransit Shared ride Other, non-public transit



Trial Applications Peer Selection Process Performance Review Metrics

Application Peer and Trend Analyses

Potential Impacts Process, Schedule, Funding

Systems/Modes SEPTA (MB, HR, CR, LR) PAAC (MB, LR) AMTRAN (MB) Endless Mountains (MB)


Progress To-Date

Materials Identification and Review Legislation: Act 44, Act 3 PPTA Performance Review

Committee Notes Prior Audits & Processes (Act 3,

TFRC) STAC White Paper Other States’ Activities Databases (NTD, dotGrant,

Census) TCRP Synthesis # 56


Progress To-Date (continued)

Data and Definitions NTD and dotGrant Data,

Definitions Applied By Mode Urban: NTD Rural: dotGrant Definitions: Act 44 as data permits

Act 44 “Special Considerations” “Circumstances Beyond Award Recipient’s

Control”

Events beyond grantee’s control which negatively affect performance, i.e., strikes, infrastructure failures, natural disasters.

Added Consideration of :» New, restructured, revised services» Discontinued services» Man-made disasters» Other (i.e., Special Events)



Perf. Review Major Analytical Components

Peer Review Trend Analysis (intra-agency) Functional Analysis (as warranted) Annual Risk Assessment by DOT

Regular Cycle 3-6 years; average 5 years More frequent – per performance data

Data Timeliness 1-2 year NTD data lag may be filled

with local or dotGrant data, where feasible.



Graduated Approach Basic Review

In compliance per base metrics and no “best practices” to document. Close out.

Step 2 Review In compliance; minor issues or Best

Practice from Basic Review. Possible Group 2, 3 metrics. Resolve via agency-developed “improvement plan” or document Best Practice.

Step 3 Review Potential or demonstrated non-

compliance. Group 2, 3 metrics; Functional review. May result in Action Plan to rectify non-compliance, potential funding implications per Act; or “Improvement Plan.”



Peer Identification Modal Number of Peers

10-12 Initial Selection 8-10 Final Selection (desired) 5 Minimum

System Types Urban compared to Urban (NTD) Rural compared to Rural (dotGrant)

Small urban if nec. to secure minimum number of peers.



Peer Review (continued) Identification Process

Process to identify and select peers based on attributes of system under evaluation.

Includes consultation with subject system.

Approaches Researched & Trialed1. Modal Characteristics Primary, Sort by

Descending Criteria2. Service Area Characteristics Primary,

Sort by Descending Criteria3. Modal Characteristics Match



Peer Review (continued) Key Criteria from NTD / dotGrant

Revenue Vehicle Hours * Revenue Vehicle Miles * Peak Vehicles Service Area Population

Other Considerations Modal:

– Fixed Guideway: # Stations, Route Miles– Bus: System Design Type, Service Type

Professional Expertise Major Generators Special Circumstances /

Considerations Climate * Car miles/hours for

FG



Peer Initial Identification Method Results#1 Modal Characteristics Primary,

Sort by Descending Criteria#2 Service Area Characteristics

Primary, Sort by Descending Criteria

Both Inadequate: Insufficient # peers for many

modes / systems Peers disparate from Act 3, TFRC

studies “Spread” inadequate for smaller

systems Over-reliance on “professional

judgment” – Add or delete prospective peers



Peer Identification Results Modal Characteristics Match

Selected Developed when #1 and #2 proved

inadequate.

Adequate # peers for all modes Good match-up to Act 3, TFRC peers. Good “spread” for smaller systems

– Many prospective peers

Minimizes need for “professional judgment” to arrive at initial set of candidates

Final peers to be selected via DOT/Agency consultation



Peer Selection Alternative Method #3 - Modal Characteristics Match Mode: Motor Bus

Evaluation Step >> 1 2 3 4 5

Subj System Anywhere PA - - - - -Metro -- USA 8.2% 2.6% 6.8% 60.6% 19.6%MTA -- USA 236.4% 157.7% 230.7% 141.5% 191.6%

Additional Considerations: Service Complexity (FG) Service Type (MB)ClimateSpecial Considerations

STEP 5 - Match Across Steps 1- 4

Prospective Peers

City StateRevenue Vehicle Hours

Revenue Vehicle Miles

Peak Vehicles

Service Area

Population

Avg. Δ From Subj

System

Draft – Discussion Only

SUMMARY:

INITIAL PEER IDENTIFICATION BY

METHOD

Peers initially identified by selection alternative. Final peers to be determined after consultation with transit agency.

19


SEPTA MBInitially Identified

Peers

Alternative 1

Transit System

Characteristics Sort

Alternative 2

Service Area Characterist

ics Sort

Alternative 3

Transit System

Characteristics Match

Washington Metropolitan Area Transit Authority

Miami-Dade Transit King County Department of Transportation – Metro Transit Division (Seattle)

Suburban Mobility Authority for Regional Transportation

Metropolitan Transit Authority of Harris County (TX)

Mass. Bay Transp. Authority

Port Authority of Allegheny Co.

Metro Transit (Minneapolis)

Maryland Transit Administration

Denver Regional Transp. District

Dallas Area Rapid Transit Orange Authority TA Chicago Transit Authority


SEPTA CR Initially Identified

Peers

Alternative 1Transit System


Alternative 2Service Area




Massachusetts Bay Transportation Authority

Northeast Illinois Regional Commuter Railroad Corporation

Metro-North Commuter Railroad Company, dba: MTA Metro-North Railroad

New Jersey Transit Corporation


Peninsula Corridor Joint Powers Board

Southern California Regional Rail Authority

MTA Long Island Railroad


SEPTA HR Initially Identified

Peers



Alternative 2Service Area Characteristi

cs Sort



Metropolitan Atlanta Rapid Transit Authority

Port Authority Trans – Hudson Corporation

Chicago Transit Authority


San Francisco Bay Area Rapid Transit District

Washington Metropolitan Area Transit Authority


SEPTA LR Initially Identified

Peers

Alternative 1

Transit System


Alternative 2

Service Area Characterist

ics Sort

Alternative 3

Transit System



San Francisco (Muni)

San Diego Trolley, Inc.

Tri-Met (Portland, OR)

LACMTA

Denver Regional Transportation District

Sacramento Regional Transit District

Dallas Area Rapid Transit

Greater Cleveland RTA

Santa Clara TA

Port Authority of Allegheny Co.


PAAC MB Initially identified

Peers

Alternative 1

Transit System


Alternative 2

Service Area


Alternative 3

Transit System


King County DOT– Metro Transit Division (Seattle)

Mass. Bay Transp. Authority

Houston Metro

Dallas Area Rapid Transit

Metro Transit -Minneapolis

MARTA – Atlanta , GA

Tri-Met (Portland, OR)

Greater Cleveland RTA

Alameda-Contra Costa Transit District (CA)



PAAC LR Initially Identified

Peers



Alternative 2Service Area Characteristi

cs Sort



Denver Regional Transp. District

Sacramento Regional Transit Dist.

Santa Clara Valley TA

Bi-State Development Agency (St Louis, MO)

Metro Transit - Minneapolis


Niagara Frontier Transportation Authority – Buffalo, NY

The Greater Cleveland RTA

Utah Transit Authority (UTA)


AMTRAN MB Initially Identified Peers

Alternative 1Transit System Characteristics

Sort

Alternative 2Service Area


Alternative 3Transit System Characteristics

Match

Harrisonburg, VA

Fargo (ND) Metropolitan Area Transit

City of Bangor (ME)– BAT

Jackson Transit Authority (TN)

Wausau Area Transit System (WI)

Santa Maria Area Transit (CA)

City of Union City Transit Div. CA)

Billings (MT) Metropolitan Transit

Missoula (MT) Urban Transp. Dist.

City of Rome (GA) Transit Department

Lawton Area Transit System (OK)

Eau Claire Transit (WI)

Muncie Indiana Transit System

Oshkosh Transit System (WI)

Cambria County Transit Auth. (PA)

Iowa City Transit

Janesville Transit System (WI)

Sheboygan Transit System (WI)

Williamsport Bureau of Transp. (PA)

Williamsburg Area Transport (VA)


Endless Mtns. TA MB

Initially Identified Peers

Alternative 1

Transit System


Alternative 2

Service Area


Alternative 3

Transit System


Altoona Metro Transit

Monroe Co TA

Schuylkill Co. PA

County of Lebanon TA

ATA of No. Central PA

Pottstown

Fayette County

Indiana County TA

Hazelton Public Transit

Performance Measures

Metrics for the Performance Review

28


Information Sources

Act 44 Section 1513 Act 3 STAC Study PPTA / PennDOT Cmte. Other States’ Practices TFRC Transit System Audits TRB / TCRP

29


Cycle

Regular 3 – 6 yr intervals (5 year avg.)

As Needed If warranted based on data

Annual Risk Assessment by PennDOT Annual dotGrant data Possibly supplement with NTD

submittal Performed by PennDOT from

agency submittals 30


Measures (continued)

3 Groups of Measures Group 1 – Act 44 Metrics

Performance Standard associated w/ these

Group 2 – Best Practices Metrics No performance standard associated

w/ these Supplement and Explain Group 1

Results Others as appropriate to situation Calculated by PennDOT during

performance review Group 3 – Customer Service

Metrics PennDOT encourages regular use by

agency

31


Measures

Group 1 – Act 44 Measures Performance Standards to be Implemented

32

Measure Source Applicability by Mode

Bus LR HR CR

Operating costs per revenue vehicle hour Act 44 ♦ ♦ ♦ ♦

Operating costs per passenger Act 44 ♦ ♦ ♦ ♦

Operating revenue per revenue vehicle hour Act 44 ♦ ♦ ♦ ♦

Passengers per revenue vehicle hour Act 44 ♦ ♦ ♦ ♦


Measures (continued)

Group 2 – Supporting Meas. – No Perf. Std.

33

Measure Source Applicability by Mode

Bus LR HR CR

Operating expense per revenue vehicle mile National Best Practice

♦ ♦ ♦ ♦

Revenue vehicle hours per employee hour National Best Practice

♦ ♦ ♦ ♦

Revenue vehicle miles per total vehicle mile (percent “live” miles)

National Best Practice

♦ ♦ ♦ ♦

Total vehicle hours per peak vehicle PPTA, Act 3 Reviews, National

Best Practice

♦ ♦ ♦ ♦

Farebox recovery ratio (operating revenue/operating expenses)

TFRC ,STAC White Paper, Act 3

Reviews

♦ ♦ ♦ ♦

General and administrative costs per total costs

National Best Practice

♦ ♦ ♦ ♦

Total vehicle hours to total fleet vehicles National Best Practice

♦ ♦ ♦ ♦

Subsidy per PassengerPPTA

♦ ♦ ♦ ♦


MeasuresHistorical

perspective/ Source

Applicability by Mode

Bus LR HR CROn-time arrival and departure PA Act 3 Guidance ♦ ♦ ♦ ♦

Frequency of service Transit ♦ ♦ ♦ ♦

Span of service National Best Practice ♦ ♦ ♦ ♦

Vehicle cleanliness PA Act 3 Guidance ♦ ♦ ♦ ♦

Fares PA Act 3 Guidance ♦ ♦ ♦ ♦

Driver courtesy PA Act 3 Guidance ♦ ♦ ♦ ♦

Safety PA Act 3 Guidance ♦ ♦ ♦ ♦

Overall rider satisfaction PA Act 3 Guidance ♦ ♦ ♦ ♦

Easy Transfers River Valley Transit ♦ ♦ ♦ ♦

Bus Stop Locations River Valley Transit ♦

Adequacy of routes (i.e., coverage) River Valley Transit ♦

Printed information River Valley Transit ♦ ♦ ♦ ♦

Telephone information National Best Practice ♦ ♦ ♦ ♦

Web page National Best Practice ♦ ♦ ♦ ♦

System map National Best Practice ♦ ♦ ♦ ♦

Number of complaints received or formally “closed-out” per month

National Best Practice ♦ ♦ ♦ ♦

Group 3 – Customer Service & Satisfaction Meas.


“Regular” Cycle

Years 1, 6

“As needed” Cycle

• Not more than every three years

• Not less than every six years

• As DOT may determine appropriate

Types of Performance Review Cycles

Years 2, 3, 4, 5

Group 1

Act 44 measures•Operating costs per revenue vehicle hour

•Operating costs per passenger

•Operating revenue per revenue vehicle hour

•Passengers per revenue vehicle hour

Additional metrics for efficiency and effectiveness

• Operating expense per revenue vehicle mile

• Revenue vehicle hours per employee hour

•Revenue vehicle miles per total vehicle mile (percent “live” miles)

•Total vehicle hours per peak vehicle

•Farebox recovery ratio (operating revenue/operating expenses)

•General and administrative costs per total costs

•Total vehicle hours to total fleet vehicles

•Subsidy per passenger (operating cost minus operating revenue divided by passengers)

Potential other metrics

•As Appropriate

Group 2

Customer satisfaction metrics

•On-time arrival and departure

•Frequency of service

•Span of service

•Vehicle cleanliness

•Fares

•Driver courtesy

•Safety

•Overall rider satisfaction

•Easy Transfers

•Bus Stop Locations

•Adequacy of routes (i.e., coverage)

•Printed and Telephone information

•Web page

•System map

•Number of complaints received per month

Group 3

35


PennDOT BPT Reporting Responsibilities and Schedules (five-year)

J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J

Annual financial audit Annual business plan reporting/monitoringPA public transportation annual performance reportAnnual risk assessments (proposed)Act 44 performance reviews (proposed regular cycle - review each year reporting on Act 44 Group 1 requirements only)Act 44 performance reviews (proposed regular cycle - review Group 1 and Group 2 measures every five years)

Transit Agency Reporting Responsibilities and Schedules (five-year)

J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J

FTA triennial review (conducted on recipients of 5307 funds; scheduled as convenient during year)Annual NTD data collection and reporting (typically based on FY end)Annual financial audit Operating and capital budgetsPA public transportation annual performance reportingOperational reviews (internal reporting, schedule determined by transit agency)Act 44 performance reviews (proposed regular cycle - review each year reporting on Group 1 requirements only)Act 44 performance reviews (proposed regular cycle - review Group 1 and Group 2 measures every five years)Customer satisfaction surveying (proposed biennial [urban] or triennial [rural] requirement, schedule determined by transit agency)External auditor general audits

Performance Review Standards Process

Progress & Thoughts to Date

37


Establishing Performance Standard

Peer Analysis to Establish Standard Metric

Peer Average, Median, Mode, Other? Accounting for current performance

(good, otherwise) Allow for Future Events, Progress

Project at current review, or at next review?

– Next review in 3-6 years

Trend Analysis Direction: Improving, Declining,

Flat 5 years in analysis; Most recent 2

years

38


Passengers / Revenue Vehicle Hour Operating Cost / Revenue Vehicle HourMode: MOTOR BUS

Operating Revenue / Revenue Vehicle Hour Operating Cost / Passenger

Sample Results: Peer Review Analysis

39


Mode: MOTOR BUS Passengers / Revenue Vehicle Hour Operating Cost / Revenue Vehicle Hour


Sample Results: Trend Analysis

40


Establishing Performance Standard (cont.)

Measuring Achievement of the Standard Approaches Under Study

Standard Deviation Approach X% of Peer Mean X% of Peer Median Quartile or Quintile Other Suggestions?

Incorporate Trend Results ? Step(s)

One > One

41


Passengers / Revenue Vehicle Hour Operating Cost / Revenue Vehicle HourMOTOR BUS PEER ANAYLSIS


Peer Average Peer Median 1 Std Dev. 5th Quintile Direction to Pass

Sample Peer Mean, Median, Standard Deviation, Quintile

Illustrative Only

42


Passengers per Revenue Vehicle Hour

Peer Average

Peer Median 1 Std Dev.

5th Quintile Direction to Pass

Illustrative Only

43


DRAFT Performance Review Outcomes

1 = Standard

MetTrend

Improving

3 = Standard Not MetTrend

Improving

2 = Standard

MetTrend

Declining

4 = Standard Not MetTrend

Declining

Standard Not Met

Performance Deteriorating

Standard Achieved or Exceeded

Performance Improving

Continuous improvement and potential

transferability to other agencies.

Action Plan required

by Act 44.

Standard Not Met

Standard Achieved or Exceeded

Action Plan required by Act 44.

May warrant further research

and possible Improvement

Plan.

04-20-09 44


Mode: MOTOR BUS Passengers / Revenue Vehicle Hour Operating Cost / Revenue Vehicle Hour


Sample Results: Trend Analysis

+.07+.12

+.57 +4.54

+.57 5 year trend / Calculated slope

Illustrative Only

45



“Continuous Improvement” Approach to Establish Performance Standards Peer Rev. + Trend Analysis +

Functional Rev. Establish Minimum Perf. Std. by

Mode Possible Performance Targets by

Mode PennDOT – Agency Discussions

Technical Assistance & Measure Progress

Achieve Standard Achieve Goal

StandardGoal

Current Performance



Conceptual ProcessPennsylvania Transit Performance Review

Draft 3/20/09

Report to Governor & General Assembly

Off Cycle Review

On Cycle ReviewResultsPennDOT

Annual ReviewRisk Assessment

PennDOT Technical Assistance

Improvement PlanPennDOT Technical Assistance

Waiver

Compliance Measurement Action Plan

FinancialPenalty

Fail

Pass

Pass

Fail

Approved

Not Approved


DRAFT Potential Act 44 System Performance Review Process

System Review Phase

As Needed Review Cycle

Regular Review Cycle (5 yr intervals)

Results

Action Plan

Improvement PlanSystem Monitoring

System Improvement and Monitoring Phase

Risk Assessment/ System Monitoring

Full Compliance

Data Collection and Analysis Phase

Customer Satisfaction Survey

4/20/2009

Group 1Performance Measures evaluated:

ACT 44 measures only

Prepare “Action Plan” with corrective

steps to improve performance

Action Plan Quarterly Progress Reports

Action Plan Approval

Department prepares annual

public transportation

performance report to Governor and

General Assembly

Department conducts trend line analysis

Data collection

Special exceptions

Examine reasons Possible “Best

Practice”

Customer satisfaction surveys (Group 3)

Regular System Review

Peer selection

Performance standards and goals developed

Reevaluated periodically

Annual Risk Assessment

SystemMonitoring

Compliance Measurement

Improvement Plan

Waiver Request

Financial Penalty

Customer satisfaction surveys (Group 3)

Improvement Plan

Customer surveys

PennDOT Requirement

PennDOT Consultation

Transit Agency Task

Joint Participation

ACT 44 Non Compliance

ApprovedPass

Fail

Yes

No

Group 2Performance Measures evaluated

Non-Regular System Review

Penn

DO

T C

onsu

ltatio

n an

d Te

ch A

ssis

tanc

e

Penn

DO

T C

onsu

ltatio

n an

d Te

ch A

ssis

tanc

eStandard Not Met and Trend Declining

Standard Not Met but Trend Improving

Standard Met and Trend Improving

Standard Met but Trend Declining

Group 2Performance Measures + Others as necessary evaluated

Publish, Transfer “Best Practice”

Functional Review


Estimated Timeline of Major Events - ASample - Preliminary Draft

5 Yr. Performance Review CycleScenario: Compliance in 1st Review, Non-compliance in 2nd Review

Draft Timeline of Events to Potential YearFinancial Reductions under Act 44 1 2 3 4 5 6 7 8 9 10

First Performance ReviewEstablish Standards & Measure COMPLYDevelop & Implement Action Plan >>>>PennDOT Technical Assistance >>>>

2nd Perf Rev: Review & Update Stds. Finding of Non-Performance FAILDevelop & Implement Action Plan >>>>Waiver PeriodPennDOT Technical Assistance >>>>Monitor ProgressFinal Progress AssessmentFinancial Penalty Applied

PennDOT Reviews / Audits X X X X X X X X X XTriennial ReviewsTransit Agency Activities * X X X X X X X X X X

* Includes quarterly dotGrant report, annual NTD report & certification (urban areas), annual audit, system operational review, etc. 5 year cycle is preliminary


Estimated Timeline of Major Events – BSample - Preliminary Draft

5 Yr. Performance Review CycleScenario: Fail 1st Review, Compliance in 2nd Review

Draft Timeline of Events to Potential YearFinancial Reductions under Act 44 1 2 3 4 5 6 7 8 9 10

First Performance ReviewEstablish Standards & MeasureFinding of Non-Performance FAILDevelop & Implement Action Plan >>>>Waiver PeriodPennDOT Technical Assistance >>>>Monitor ProgressFinal Progress AssessmentFinancial Penalty Applied

2nd Perf Rev: Review & Update Stds. COMPLYDevelop & Implement Action Plan >>>>PennDOT Technical Assistance >>>>

PennDOT Reviews / Audits X X X X X X X X X XTriennial ReviewsTransit Agency Activities * X X X X X X X X X X

* Includes quarterly dotGrant report, annual NTD report & certification (urban areas), annual audit, system operational review, etc. 5 year cycle is preliminary


Next Steps

Finalize Perf. Review Process Method to Develop Performance

Standards Peer Analyses Trend Analyses Functional Reviews

Overall Process Map and Description

Impacts of Inadequate Performance Process* Process Impacts

* Test vs. 4 systems / 8 modes


Questions and Discussion

act 44 performance standards regulation development april 24, 2009 bob kaiser - michael baker jr.,...

Documents

draft discussion

draft discussion purposes

questions discussion

performance measures

draft report of findings

overall process

poor exemplary performance

document exemplary performance