Yes. A rail transit system does not need to receive federal funds to qualify for this program. Eligible rail transit systems must report to the National Transit Database (NTD) to be included in the apportionment and grant funding may only be used for those systems that report to the NTD or intend to report to the NTD. The applicant or the rail transit system that is currently not reporting to the NTD, e.g., those rail transit systems in the engineering or construction phase of development, should submit a letter of intent that the rail transit system at issue will report to NTD and comply with all applicable Federal requirements.