A final procedural and institutional impact involves FTA's current process for reviewing prospective New Starts projects. Several commented that FTA's process does not reflect the fast-track possibilities of innovative project delivery approaches such as design-build. As currently structured the FTA approval process was described as very linear, sequentially moving projects from preliminary engineering to final design to FFGA without allowing for concurrency in the planning process, a vestige of a time when design-bid-build was the only delivery approach employed for New Starts projects. Rigorous risk assessments identifying major project risks and mitigation strategies are required prior to FFGA, but construction cannot begin until the agency enters into a FFGA with FTA. One agency suggested that FTA modify its evaluation process so that a FFGA may be entered into without first completing final design, stating that conclusive evidence demonstrating to the Project Management Officer (PMO) that Federal risk is minimized should be sufficient to advance a project. Another stated that FTA's risk assessment requires the sponsoring agency to develop designs early in the development process as a condition of grant award, which may foreclose opportunities to apply innovative delivery techniques because 60 to 65 percent design detail is required to satisfy FTA requirements.