Bottom Line Up Front
Secretary of Transportation Sean Duffy has issued DOT Order 2100.7, rescinding several Biden-era policy directives and refocusing federal transportation funding around economic merit, infrastructure delivery, and cost efficiency. Agencies competing for IIJA discretionary dollars need to understand how the evaluation criteria have shifted — and position their projects accordingly.
A Decisive Shift in Federal Priorities
On March 10, 2025, Secretary Duffy officially rescinded several prior USDOT policy directives, describing the move as a return to building infrastructure that moves people and commerce safely. The new framework under DOT Order 2100.7 establishes a clear set of evaluation priorities for how the federal government will assess, fund, and oversee transportation projects going forward.
For transportation agencies, MPOs, and project sponsors pursuing federal discretionary grants, this isn’t a subtle policy tweak. It’s a wholesale reorientation of what USDOT values — and what it doesn’t.
2100.7
New DOT Order
March 10
Effective date, 2025
Jan 20
Grant Agreement Cutoff
What DOT Order 2100.7 Prioritizes
The new framework signals a clear return to core infrastructure delivery metrics. Projects that demonstrate economic impact, cost discipline, and alignment with national mobility goals will have a distinct advantage in future federal funding rounds.
- Rigorous cost-benefit analysis for all discretionary awards
- Community impact assessments tied to economic outcomes
- Preference for public-private partnerships and user-pay models
- Alignment with national economic and infrastructure goals
- Priority for projects supporting mobility and economic opportunity
- Strict compliance with federal law across all recipients
Key Takeaway
The emphasis is clear: economic merit and delivery efficiency are now the primary evaluation criteria. Agencies that can demonstrate shovel-readiness, strong benefit-cost ratios, and leveraged local match funding will be best positioned for the next round of IIJA discretionary grants.
— Secretary of Transportation Sean Duffy
Existing Grants Under Review
In a follow-up directive issued March 11, Secretary Duffy instructed USDOT administrators to review pending discretionary grant awards from the previous administration. Any project that had not yet entered into a formal grant agreement by January 20 is now subject to reassessment.
Projects at Risk
Awards that include elements tied to DEI policies, climate change initiatives, Environmental Justice, gender-specific components, recreational bicycle infrastructure, or EV charging programs may face renegotiation — or cancellation. This review stems from executive orders issued on Day One calling for the elimination of DEI, EJ, and EV-related government spending.
Industry Outlook
The American Road & Transportation Builders Association (ARTBA) expects many affected projects will eventually move forward — assuming alignment with the updated evaluation criteria. No formal timeline has been provided for the review process, but agencies should prepare for scrutiny of any pending applications that contain the flagged elements.
Questions About Federal Funding Strategy?
If you’re navigating IIJA discretionary grants or positioning a project under the new USDOT framework, I’m happy to discuss what I’m seeing on the ground.
Positioning for Future Funding
For agencies and project sponsors, DOT Order 2100.7 provides a clear policy roadmap. The projects that win federal dollars going forward will share common characteristics: strong economic justification, demonstrated delivery capability, leveraged non-federal funding, and alignment with core transportation infrastructure objectives.
Strategic Positioning
Projects that are economically sound, non-ideological, and focused on traditional infrastructure delivery will have a distinct advantage. Agencies should begin reassessing pending applications and future submissions to ensure alignment with the updated evaluation framework — particularly around benefit-cost analysis and match funding narratives.
The Connector’s Competitive Position
The Capital SouthEast Connector aligns directly with the principles outlined in DOT Order 2100.7. It’s the kind of project the new framework was designed to elevate.
Project Alignment
Shovel-ready with final design and permitting underway. Strong economic justification — improving freight mobility, reducing regional congestion, and supporting housing and job access. Leveraged funding including a $25 million RAISE grant and a pending $20 million TCEP request. Bipartisan support from local, state, and federal representatives. And a core focus on highway infrastructure capacity, safety, and economic impact.