Transit Asset Management: Top 12 Frequently Asked Questions
The questions included on this page are the top 12 most frequently asked that address the requirements for complying with the Transit Asset Management (TAM) rule as set forth in 49 CFR part 625. These FAQs are not a substitute for reviewing the TAM rule.
- Who must comply with the TAM rule?
- How do transit providers comply with the TAM rule?
- What level of change requires a complete TAM plan update?
- Does FTA require that transit agencies continue to report AIM data and targets following the first TAM plan update?
- Does FTA require that TAM plans be signed by agency leadership?
- How is the TAM plan linked to Public Transportation Agency Safety Plan (PTASP)?
- How does TAM plan compliance impact the allocation of federal funds?
- What assets must I include in a TAM asset inventory?
- What does “annual condition assessment report” in rule section 625.53(b) mean?
- How do I know if I have direct capital responsibility for a facility?
- The Default ULB Cheat Sheet states that transit agencies can adjust their ULB with approval from FTA. Can FTA provide guidance on the process?
- Who needs to approve the TAM Performance Measure targets before we submit them to the MPO?
- Do MPOs have to update their TAM targets annually? Even if they update their TIP or MTP more frequently than Planning regulations require?
A complete list of all FAQs is available on the Archived Questions and Answers page.
The TAM rule applies to all recipients of Chapter 53 funds that either own, operate, or manage capital assets used in providing public transportation services.
|The rule applies to you||The rule does NOT apply to you|
|If you own an FTA-funded capital asset used in providing public transportation services, then you must comply with the TAM rule, even if you do not operate or manage that asset.||If you do not receive Chapter 53 funds and you have never received Chapter 53 funds, then the TAM rule does not apply to you.|
|If you manage or operate an FTA-funded capital asset used in providing public transportation services, then you must comply with the TAM rule, regardless of who owns that asset.||If you receive FTA funds, but do not use those funds for public transportation services, then the TAM rule does not apply to you (e.g., Planning or Research grants)|
NOTE: Public Transportation is defined by law as “regular, continuing shared-ride surface transportation services that are open to the general public or open to a segment of the general public defined by age, disability, or low income.” 49 U.S.C. § 5302(14).
An example of public transportation service to a segment of the general public is service for all senior citizens or all persons with disabilities in a particular town or county. However, if you are providing a courtesy shuttle service for patrons of a specific establishment with a senior citizen clientele, then your service is not considered to be public transportation. Similarly, if you provide service that requires membership in an organization such as a church or club, then, your service is not considered to be public transportation.
In addition, commuter rail service providers operating on the Northeast Corridor (NEC) should also reference 49 USC §24904(c) for additional asset management regulations.
Transit providers must complete several key actions to comply with the TAM rule, including developing a TAM plan and submitting two reports to the NTD annually: a data report and a narrative report. More detailed descriptions of each requirement will follow in the FAQ.
Develop TAM plan. All transit agencies that own, operate, or manage capital assets used in the provision of public transportation and receive federal financial assistance under 49 U.S.C. Chapter 53 either as recipients or subrecipients must develop a TAM plan. A TAM plan is a tool that will aid transit providers in:
- Assessing the current condition of its capital assets
- Determining what the condition and performance of its assets should be (if they are not already in a state of good repair)
- Identifying the unacceptable risks, including safety risks, in continuing to use an asset that is not in a state of good repair
- Deciding how to best balance and prioritize reasonably anticipated funds (revenues from all sources) towards improving asset condition and achieving a sufficient level of performance within those means
TAM plans must include at a minimum an asset inventory, condition assessments of inventoried assets, and a prioritized list of investments to improve the state of good repair of their capital assets.
Complete NTD asset inventory module (AIM) report. You must develop an inventory of your assets, and you must report the data and other information required to the NTD asset inventory module report annually. Additional data required by NTD includes information used to calculate the TAM metrics.
Conduct and report facility condition assessments. You must assess the condition of all the capital assets in your TAM plan, and you must report the condition assessments for facility category assets to the NTD for a portion of your agency’s facility capital assets. Every year thereafter, you must report the condition assessments for another proportion of your agency’s facility capital assets, until all of the condition assessments for all facility capital assets have been reported to the NTD. You must then renew the process of conducting condition assessments.
Set Performance Targets. You must set targets annually for the performance of your assets and submit those targets to the NTD as part of your annual data submission. Each asset category has its own performance measure by which to set targets:
- Rolling stock: % of revenue vehicles exceeding ULB
- Equipment: % of nonrevenue service vehicles exceeding ULB
- Facilities: % of facilities rated under 3.0 on the TERM scale
- Infrastructure: % of track segments under performance restriction
Submit narrative report to the NTD. You must submit an annual narrative report to the National Transit Database that provides a description of any change in the condition of the provider’s transit system from the previous year and describes the progress made during the year to meet the performance targets set in the previous reporting year.
If an agency experiences a significant unexpected change that cannot be addressed with a simple amendment to the existing TAM plan, a full TAM plan update (revision) is required. For example, asset damage from a hurricane, approval of a local tax for transit, or other changes to the TAM planning context would require a full update, whereas a new Accountable Executive might not. Agency TAM plans should establish thresholds for significant change based on their assets and policies, in order to ensure consistency in how updates occur and how often. These thresholds could be identified in Agreements with Stakeholders, the Evaluation Plan, and/or Group Plan Sponsor communication.
Does FTA require that transit agencies continue to report AIM data and targets following the first TAM plan update?
Yes. The TAM Rule and NTD regulation require annual submission of asset inventory data and narrative reports, and an updated TAM Plan at least every four years. While an agency is updating its TAM plan, it should continue submitting the NTD AIM and target data consistent with their NTD reporting deadline. Please review the Getting Started webpage for a list of upcoming reporting deadlines.
There is no specific signature requirement for the TAM plan, although documented approval by the Accountable Executive is required. Agencies may determine the best way to present this documentation. For more information, please see the FAQ on TAM compliance.
In July 2018, FTA published the Public Transportation Agency Safety Plan (PTASP) final rule (49 C.F.R. Part 673) to improve public transportation safety by guiding transit agencies to more effectively and proactively manage safety risks in their systems. It requires certain recipients and sub-recipients of FTA grants that operate public transportation to develop and implement safety plans that establish processes and procedures to support the implementation of Safety Management Systems (SMS).
Through the implementation of the Transit Asset Management (TAM) Plan, required under 49 C.F.R. Part 625, a transit agency should consider the results of its condition assessments while performing safety risk management and safety assurance activities. The results of the condition assessments, and subsequent SMS analysis could inform a transit agency’s TAM Plan elements, specifically investment priorities. The Accountable Executive has the ultimate responsibility for decision-making throughout this process and for approving both the TAM plan and the PTASP.
Please note, the PTASP final rule applies to only Section 5307 recipients and sub-recipients, and the TAM rule applies to all operators of public transit.
At present, neither compliance with the TAM rule nor any TAM-related materials collected by FTA impacts the allocation of any federal funds.
There are four categories of capital assets that must be included in a TAM asset inventory: facilities, equipment, rolling stock, and infrastructure. Your TAM plan must include an inventory of all the capital assets in each of the categories that you own, operate, or manage. More information on what assets must be included in your TAM asset inventory can be found in the “What do I need to report to the NTD” section of this FAQ.
In those instances where capital assets are shared among multiple transportation agencies, the agencies must determine, collectively, which of them is responsible for conducting the condition assessment of that asset, even though all of those agencies will be responsible for including that asset in their own asset inventories and in reporting data on that asset to the NTD.
The annual condition assessment report refers to the updated condition assessment information that is part of your TAM plan, which should be made available to your State and MPO, once per year as appropriate.
The TAM final rule requires you to assess all assets for which you have direct capital responsibility, including those that are owned by someone else but for which you have at least partial direct capital responsibility.
|Condition Assessment Required and Reported to NTD||Condition Assessment Not Required|
You must consider the financial obligations you have to the condition of the asset. You must assess the condition of the assets listed in your asset inventory for which you have direct capital responsibility.
|You have direct capital responsibility||You do NOT have direct capital responsibility|
|You own the asset||You do not own the asset AND you are not responsible for replacing, overhauling, refurbishing, or conducting major repairs on that asset, or the costs of those activities are not itemized as a capital line item in your budget.|
|You jointly own the asset with another entity|
|You are responsible for replacing, overhauling, refurbishing, or conducting major repairs on that asset, or the costs of those activities are itemized as a capital line item in your budget.|
NOTE: Performing minimal preventive maintenance work on an asset, like cleaning, does not in itself indicate that you have direct capital responsibility for the asset. An infrastructure asset itemized as capital line item in budget does not necessarily mean you have direct capital responsibility; you must also have management or oversight responsibilities for that line item project.
The Default ULB Cheat Sheet states that transit agencies can adjust their ULB with approval from FTA. Can FTA provide guidance on the process?
When entering your fleet data in the NTD, you will have the option to either accept the pre-populated default ULBs or submit your customized ULBs. In cases where the ULB is significantly different from the default ULB value, you may be prompted to verify it is not a typo and/or submit justification for the value. If FTA accepts your NTD report, then it accepts your customized ULB.
The TAM Rule requires that the transit provider’s accountable executive approve its TAM plan, which includes the performance measure targets. Any other aspects of your approval process are considered a local decision.
Do MPOs have to update their TAM targets annually? Even if they update their TIP or MTP more frequently than Planning regulations require?
No, MPOs do not have to update their TAM targets annually. However, in consultation with the State DOTs and transit providers, they may choose to revise or maintain their performance targets when they update their TIPs or MTPs regardless of the frequency of those updates. Please note that FTA Planning regulations do not require MPOs to update their TIPs or MTPs annually.
MPOs are also not required to update or revisit their TAM targets every time a State DOT or transit provider updates its TAM targets. However, best practices would encourage consultation and communication with State DOTs and transit providers to ensure alignment of targets.
The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.