A. Because you have not yet acquired the vans and instituted expanded service, you probably will not be required to implement your "process to solicit and consider public comment before...carrying out a major reduction of transportation," as implied by 49 U.S.C. 5307(d)(1)(I). However, if a "major reduction of transportation" would be the result of your revised plans to use some of the vans to replace others in use, then it would be desirable to use its "process to solicit and consider public comment," particularly if you used Section 5307 funds or funds subject to Section 5307 requirements to purchase the vans.
You will need to present this question to your FTA regional grant manager. The regions normally have several grants managers. Some assign projects to managers individually while some of the regions assign a whole state to a manager and have that manager pick up anything that comes in from their state(s). If you look at your grant in the TEAM system, it will identify an FTA manager. (Revised: May 2010)