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BOOK ill PAL 88 representatives of the general purpose local governments within the MPO area agreed that the IRCSD should have voting representation on the MPO Board, FDOT disagreed. According to FDOT, Chapter 339, F.S. specifically listed criteria for MPO membership and that criteria would not allow a school board to have voting representation on an MPO Board. 1993 Apportionment Plan Table 3 depicts the MPO Policy Board structure established by the 1993 Indian River County MPO apportionment plan. As indicated in that table, the MPO Policy Board had nine voting members. These included four County Commissioners, two Vero Beach City Councilmen, one Sebastian City Councilman, one Fellsmere City Councilman, and one Indian River Shores Town Councilman. The MPO Board also included as nonvoting members one representative of the Town of Orchid and one representative of the IRCSD. As structured, the MPO Board had direct representation from five of the six general purpose local governments within the MPO area. Only the Town of Orchid, which had a 1990 population of 10, did not have direct representation on the MPO Board. 1999 Apportionment Plan Analysis Since 1993, FDOT's position regarding school board voting representation on MPO Policy Boards has changed. For example, FDOT, in addressing initiatives by the Broward MPO to add a school board member to its MPO Policy Board, has interpreted Chapter 339, F.S. to allow school board representatives to serve as voting members of MPO Boards. This is based on Chapter 339's provision that representatives of agencies operating major modes of transportation may have voting representation on MPO Boards, and a recognition that school boards are agencies operating a major mode of transportation. As written, Chapter 339.175(2)a, F.S., states that an MPO "may include, as part of its apportioned voting members, an ... official of an agency that operates or administers a major mode of transportation." In Indian River County, the Indian River County School District (IRCSD) provides a greater number of trips over a greater number of miles with a larger fleet than any other transportation provider, including the County's public transportation provider. Unlike the County, municipalities, and other major transportation providers, such as the Community Coach public transportation system and the County's three public airports, all of which have direct or indirect voting representation on the MPO Policy Board, the IRCSD does not have direct or indirect voting representation on the MPO Board. Although adding an IRCSD voting member to the MPO Board does not affect the population or percent distribution of the MPO's 1993 apportionment, it does require updating the MPO's original 1993 apportionment plan because it changes the structure of the MPO Board. This 1999 apportionment plan addresses the addition of an IRCSD voting member to the MPO Board and contains the information required in an apportionment plan by Chapter 339.175, F.S. Table 4 depicts the Policy Board structure established by the Indian River County MPO's 1999 apportionment plan. The 1999 plan differs from the 1993 plan by the addition of one voting member from the IRCSD. As a comparison of Table 4 and Table 3 indicates, providing the IRCSD with voting representation on the MPO Policy Board does not affect the population or percent distribution of the MPO's 1993 apportionment. This is because the IRCSD serves the entire County rather than a geographic subarea Therefore, the geographic population and the percent representation served by the MPO Board's 1993 members will not change. In fact, the MPO Board will more accurately represent and reflect the major transportation providers in the County without reducing the representation of the current MPO Board members. October 19, 1999 52