APTA to FTA: ‘Undertake a Zero-Based Review of All CIG Requirements’

Written by Marybeth Luczak, Executive Editor
Massachusetts Bay Transportation Authority’s $2.3 billion Green Line Extension is among the projects receiving Capital Investment Grants from the Federal Transit Administration.

Massachusetts Bay Transportation Authority’s $2.3 billion Green Line Extension is among the projects receiving Capital Investment Grants from the Federal Transit Administration.

The American Public Transportation Association (APTA) has responded to the Federal Transit Administration’s (FTA) call for Capital Investment Grants (CIG) Program feedback, and has updated its dashboard of CIG projects in the pipeline.

FTA on July 15 released a Request for Information (RFI) on the CIG Program, seeking suggestions from transit stakeholders—from transit authorities to planning officials to the private sector—on evaluation process improvements (download below). Feedback was due Oct. 13.

Among the comments APTA provided on behalf of its 1,500 public- and private-sector members:

• “The transparency and clarity of the CIG criteria allow our members to determine early in the planning process whether they have a project that is likely to qualify, and therefore is worth additional investment in time and local funds. We encourage FTA to strongly consider this need for transparency and clarity for project sponsors as it considers changes to the program process requirements and evaluation measures.”

• “APTA and its members greatly appreciate the critical support that Congress and FTA have provided to public transit agencies throughout the COVID-19 pandemic. Under its CIG reporting requirements, FTA has allowed agencies to use pre-pandemic financial, ridership, and other data to support the travel forecasting, financial analysis, and other measures. Given that the pandemic is continuing to have a severe negative effect on transit ridership and agency finances, APTA believes FTA should continue this practice for at least the next few years. Similarly, FTA should not penalize agencies for pandemic-related service reductions when assessing the ‘Current Capital and Operating Condition.’”

• “As FTA considers ways to improve the CIG program and processes, we urge the agency to undertake a zero-based review of all CIG requirements. Beginning with enactment of the Transportation Equity Act for the 21st Century in 1998, both Congress and FTA have repeatedly layered additional requirements on the CIG program, resulting in a less than clear process. APTA urges both Congress and FTA to adopt CIG reforms to strengthen the CIG program, expedite approval, and ensure that beneficial projects across the nation are delivered in a timely manner.”

In January 2021, FTA signed a Full Funding Grant Agreement under its CIG Program for Valley Metro’s South Central Light Rail Extension/Downtown Hub Project in Phoenix.

• “We strongly support the CIG reforms included in both the House- and Senate-passed versions of H.R. 3684, the Infrastructure Investment and Jobs Act. We are hopeful that Congress will enact this critical legislation this fall, and we urge FTA to immediately begin planning to implement the statutorily required changes to the CIG program. In addition, as part of FTA’s review of the CIG program, we urge the agency to further assess the need for each and every administrative requirement included in the program. We also urge the agency to review its internal project review processes and take steps to reduce the necessary review times. In addition, to further expedite CIG projects, FTA needs sufficient staff to complete the reviews and approvals required by the CIG process. Many, if not all, FTA staff working to review CIG projects are overworked. This situation has forced FTA regional offices to hire consultants to support the National Environmental Policy Act (NEPA) review of projects, sometimes at the expense of project sponsors. APTA urges Congress and the U.S. Department of Transportation (DOT) to support FTA with sufficient funding and authorization to hire the staff necessary to manage the pipeline of proposed CIG projects.”

The association also provided detailed answers to 19 FTA-posed questions. Download below:

APTA President and CEO Paul P. Skoutelas

“APTA strongly supports the CIG program, and we are grateful for the opportunity to provide this input,”APTA President and CEO Paul P. Skoutelas said. “We are also excited that FTA’s RFI suggests that the CIG program expand ways for FTA to consider issues of equity, access to opportunity, human health, and other ways that transit can improve the lives of Americans.”

According to APTA, the CIG Project Pipeline includes 67 projects totaling nearly $28 billion of unmet CIG funding. The association now offers an updated dashboard (download below) of all CIG projects, their differing stages of project development, and the amount of funds allocated for each—with links to current project profile, as updated by FTA. “This important advocacy tool shows the unmet need that remains for current CIG projects and how much funding remains available by project type,” APTA said.

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