No. The FHWA may only make direct grants to non-State DOT entities where such entities are specified in statute. It is clear that Sections 1301, 1302, and 1306 require that funds be distributed to a State.
The FHWA's long-standing practice is to distribute funds through the State DOTs. This policy is based on the FHWA’s interpretation of 23 U.S.C. more.
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