Audit of the Pioneer Valley Transit Authority Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Pioneer Valley Transit Authority.

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of the Pioneer Valley Transit Authority (PVTA) for the period July 1, 2022 through June 30, 2024.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. 

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective	Conclusion
To what extent did PVTA establish and implement policies and procedures to identify and mitigate potential causes of electrical fires in its battery electric buses (BEBs) in accordance with Sections 673.25(b)(1)(2)(i), (c)(1), and (d)(1) of Title 49 of the Code of Federal Regulations (CFR); Section IV of the “PVTA Agency Safety Plan”; and Appendix B of the Springfield Area Transit Company and Valley Area Transit Company’s (SATCo/VATCo’s) “Electrical Safety Plan”?	To an insufficient extent; see Findings 1 and 2
Did PVTA ensure that its two contracted operating companies performed preventative maintenance on its BEBs in accordance with Section B of SATCo/VATCo’s “Vehicle Maintenance Plan” and Section 1 of the University of Massachusetts Transit Services’ (UMTS’s) “Vehicle Maintenance Plan”?	No; see Finding 3

To accomplish our audit objectives, we gained an understanding of the PVTA internal control environment relevant to our objectives by reviewing applicable policies and procedures and by interviewing PVTA employees, PVTA management, and contracted operating company employees. We also evaluated the operating effectiveness of internal controls related to the maintenance foreperson’s approval of preventative maintenance inspections of BEBs. In addition, to obtain sufficient, appropriate evidence to address our audit objectives, we performed the procedures described below.

Safety Hazard Mitigation for BEBs

To determine to what extent PVTA established and implemented policies and procedures to identify and mitigate potential causes of electrical fires in its BEBs in accordance with 49 CFR 673.25(b)(1)(2)(i), (c)(1), and (d)(1); Section IV of the “PVTA Agency Safety Plan”; and Appendix B of SATCo/VATCo’s “Electrical Safety Plan,” we took the following actions:

• We examined the “PVTA Agency Safety Plan” that was in place during the audit period to ensure that PVTA identified potential safety hazards and identified how to mitigate them. We followed up with PVTA on any inconsistencies when it did not identify potential safety hazards for BEBs. 
• We reviewed the minutes of all 18 of PVTA’s Safety Committee meetings that were held during the audit period to ensure that PVTA identified potential safety hazards related to BEBs in these meetings. 
• We also reviewed minutes for the four PVTA Safety Committee meetings that were held between January 5, 2022 and May 4, 2022 (before the audit period) to determine whether PVTA identified potential safety hazards related to BEBs that would require safety risk assessments and hazard mitigation plans during the audit period.
• We requested evidence of all risk assessment matrices completed during the audit period so that we could determine the potential safety hazards associated with BEBs.
• We requested evidence that all Hazard Mitigation Action Worksheets were completed during the audit period so that we could determine whether PVTA identified and mitigated the potential safety hazards associated with BEBs.
• We inspected training attendance logs and completion certificates for all 19 qualified maintenance employees to determine whether they completed the training required for qualified maintenance employees according to SATCo/VATCo’s “Electrical Safety Plan.” Specifically, we tested whether each contracted employee completed training for CPR, first aid, bloodborne pathogens, the National Fire Protection Association’s 70E (Standard for Electrical Safety in the Workplace), Proterra BEBs, and New Flyer BEBs, in accordance with SATCo/VATCo’s “Electrical Safety Plan.”

For this objective, we found certain issues during our testing—namely, that PVTA did not ensure that its contracted operating companies established and implemented sufficient policies and procedures to identify and mitigate potential causes of electrical fires in its BEBs in accordance with 49 CFR 673.25(b)(1)(2)(i), (c)(1), and (d)(1) and Section IV of the “PVTA Agency Safety Plan.” See Finding 1 for more information.

Additionally, we found that PVTA did not provide safety training to all employees and vendors who performed preventative maintenance on BEBs in accordance with SATCo/VATCo’s “Electrical Safety Plan.” See Finding 2 for more information.

Preventative Maintenance of BEBs

To determine whether PVTA ensured that its two contracted operating companies performed preventative maintenance on its BEBs in accordance with Section B of SATCo/VATCo’s “Vehicle Maintenance Plan” and Section 1 of UMTS’s “Vehicle Maintenance Plan,” we took the following actions: First, we inspected hardcopy preventative maintenance work orders and checklists for all 76 preventative maintenance procedures performed on BEBs during the audit period. We calculated the difference between the recorded mileage on each BEB’s consecutive preventative maintenance checklists to determine whether preventative maintenance was performed within 600 miles above or below the 6,000‑mile maintenance schedule. We also examined all preventative maintenance checklists to ensure that the maintenance employee assigned to perform this work completed all required work listed in the preventative maintenance schedule.

For this objective, we found certain issues during testing—namely, that PVTA did not ensure that preventative maintenance procedures were performed on BEBs in accordance with Section B of SATCo/VATCo’s “Vehicle Maintenance Plan” and Section 1 of UMTS’s “Vehicle Maintenance Plan.” See Finding 3 for more information.

Data Reliability Assessment

We sought to gain an understanding of software controls and data management processes to determine the reliability of the BEB preventative maintenance data held by PVTA’s contracted operating companies. This information was kept in their enterprise asset management (EAM) software. To do this, we conducted interviews and system walkthroughs with PVTA management and the contracted operating companies’ employees who were knowledgeable about the data and responsible for its oversight. We tested selected information system controls (access controls and security management). Through this testing, we found that neither PVTA nor its contracted operating companies had established adequate internal controls over the EAM software, which we discussed with PVTA management.

From SATCo/VATCo’s EAM software, we obtained a list of all 64 BEB preventative maintenance checklists from the audit period. We reviewed the parameters that SATCo/VATCo used to generate this list from its EAM software to ensure that the list included only BEB preventative maintenance checklists that were completed during the audit period. We also checked the list for duplicate records and dates outside the audit period. We randomly selected 10 hardcopy preventative maintenance checklists and compared the information in them—including BEB numbers, mileage, and work order dates—to the corresponding information on the list of preventative maintenance checklists to determine the completeness of the list. We also selected 10 records from the list of preventative maintenance checklists and compared the information in them—including BEB numbers, mileage, and work order dates—to the corresponding information on the hardcopy checklists to determine the accuracy of the list.

From UMTS’s EAM software, we obtained a list of all 12 BEB preventative maintenance checklists that were completed during the audit period. We reviewed the parameters that UMTS used to generate this list from its EAM software to ensure that the list included only BEB preventative maintenance checklists that were completed during the audit period. We also checked the list for duplicate records and dates outside the audit period. We randomly selected six hardcopy preventative maintenance checklists and compared the information on them—including BEB numbers, mileage, and work order dates—to the corresponding information on the list of preventative maintenance checklists to determine the completeness of the list. We also selected six records from the list of preventative maintenance checklists and compared the information in them—including BEB numbers, mileage, and work order dates—to the corresponding information on the hardcopy checklists to determine the accuracy of the list.

Based on the results of the data reliability assessment procedures described above, we determined that the information we obtained during our audit was sufficiently reliable for the purposes of our audit.

Date published:	July 1, 2026