The American Road and Transportation Builders Association (ARTBA) supports the Federal Transit Administration's (FTA) proposed guidance allowing for the acquisition of rights-of-way prior to completing environmental reviews for transit capital projects. ARTBA represents 6,000 transportation construction industry members undertaking federal projects subject to environmental reviews. Allowing early rights-of-way acquisition as the guidance proposes could reduce project delays by permitting multiple tasks to occur simultaneously. Further, the Moving Ahead for Progress in the 21st Century Act authorized early acquisition of rights-of-way for transit projects, and ARTBA recommends FTA apply the new guidance broadly to maximize time savings from an earlier start to the acquisition process.