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Frequently Asked Questions

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During Project Development, prior to the completion of the environmental review process required under the National Environmental Policy Act (NEPA), FTA will work with project sponsors to assess the strengths and weaknesses of alternatives still under consideration and provide technical assistance on how to meet the requirements to enter Engineering. Technical assistance may include workshops or other methods focusing on the readiness requirements to enter Engineering.

Formal oversight will generally begin at the completion of NEPA and will be tailored based on the how far the project has advanced in design, the complexity of the project, and the project sponsor’s capability to undertake engineering and construction.


Funds allocated for response, recovery, and rebuilding may be used for eligible expenses according to statute and FTA regulation, including:

  • Repair / replacement of damaged or destroyed assets to a state of good repair;
  • Emergency operating expenses for evacuations, temporary emergency service, disaster preparation, and temporary repairs/protective measures.

Funds allocated for resilience projects may be spent on capital projects that are designed and built specifically to address existing and future vulnerabilities to damages from disasters. Please see FTA’s Emergency Relief Manual for further detail.


PIPP waiver and modification requests will be reviewed by FTA based on the following criteria:

  1. Are the proposed experimental features prohibited under current policies and procedures?
  2. Does the waiver or modification request extend beyond procurement issues covered by the PIPP?
  3. Will an approved waiver or modification request improve the delivery time, quality, and/or cost of the project?
  4. Will an approved waiver or modification influence future Federal public transportation policy and procedures?
  5. Is there a plan by the project sponsor for evaluating how the features of the waiver or modification will contribute to the overall success of the project?

The overall intent of the PIPP is to foster innovation and explore the full range of opportunities to make the project delivery process more efficient. Any proposals that meet this intent and are consistent with the criteria noted above will be given strong consideration.


A local government authority includes:

  • a political subdivision of a state,
  • an authority of at least one state or political subdivision of a state,
  • an Indian tribe, or
  • a public corporation, board, or commission established under the laws of a state.

By law, FTA evaluates and rates Capital Investment Grants Program New Starts or Core Capacity projects prior to allowing them into the Engineering phase. FTA evaluates and develops ratings for the project justification and local financial commitment criteria.

FTA also reviews the project sponsor’s Project Management Plan and subplans to ensure that the sponsor has the technical capacity and capability to deliverthe project.  Lastly, FTA reviews the project definition, scope, cost and schedule for reasonableness, undertakes and completes a risk assessment. These reviews may be expedited based on factors including the complexity of the project and the project sponsor’s management capacity and capability.


This will vary depending on the complexity of the waiver or modification request and the project. FTA will strive to respond to complete applications within 60 days. If FTA determines an application is incomplete or if FTA has questions, FTA will not wait 60 days to respond, but will notify the applicant as soon as it makes that determination.


The appropriate documentation may vary depending on the source of local match. Examples could include a city council or board resolution to provide local match for the project or a letter from the state attesting to the availability of state funding for the project.


FTA decided to set aside $50 million of the overall $330 million appropriation for latent damages and other emergency-related expenses from Hurricanes Harvey, Irma, and Maria that may arise in the future.


FTA plans to conduct a risk assessment of New Starts and Core Capacity projects prior to entry into the Engineeringphase of its Capital Investment Grants program.  FTA may perform updates to the risk assessment and scope, cost, and schedule reviews prior to awarding a construction grant agreement.  

For Small Start projects, scope, cost and schedule reviews and a risk assessment may be conducted during the Project Development phase.  


No. Operating expenses are not eligible under this program and cannot be counted toward the total project cost in determining the local cost share. Eligible sources of local match include the following:

  • cash from non-government sources of that revenues from providing public transportation services;
  • revenues derived from the sale of advertising and concessions;
  • amounts received under a service agreement with a state or local social service agency or private social service organization;
  • revenues generated from value capture financing mechanisms; or
  • funds from an undistributed cash surplus; replacement or depreciation cash fund or reserve; new capital; or allowable in-kind contributions.

FTA’s ER program functions on a reimbursement basis. The allocation specifies the maximum amount currently available to each State/Territory/jurisdiction based primarily on their proportionate share of emergency expenses and damages to their public transportation assets and infrastructure arising from Hurricanes Harvey, Irma, and Maria.

For recovery projects, FTA staff worked closely with transit officials in the affected regions ahead of the hurricanes’ landfall to advise them of ER program requirements and ensure they had the knowledge and resources in place to carefully track emergency expenditures for potential reimbursement.  For resilience projects, specifically, to receive FTA ER funding, the State or Territory must also prepare a program of projects and submit it to FTA for advance review and approval before moving forward with expenditures.

As grants applications are developed, FTA will review the proposed activities to ensure they are only used for eligible purposes and are in compliance with all applicable Federal requirements.  FTA will also include special grant conditions for all Hurricane Harvey, Irma, and Maria Emergency Relief funds.

Once projects are awarded in grants, recipients are required to submit Federal Financial Reports and Milestone Progress Reports to FTA to provide information about the status of the projects.  FTA will also undertake additional oversight, including Triennial Reviews and State Management Reviews and other reviews as necessary.

For resilience projects, specifically to receive FTA ER funding, the State or Territory must prepare a program of projects and submit it to FTA for advance review and approval before moving forward with expenditures.


Readiness will vary depending on the elements of the project development process that are being modified or changed. Generally, a PIPP request for a waiver or modification will be submitted prior to the start of a project, but there may be circumstances later on in the process where funding mechanisms change or some other fundamental issue leads to requesting a waiver or modification under the PIPP.


FTA has continued to refine the technical methods and adjust the probability thresholds it uses to undertake the risk assessment based on historic data from previous projects. When determining the reasonableness of a project sponsor’s cost and schedule, FTA reviews the estimates to determine whether they include reasonable assumptions or whether adjustments need to be made. FTA then examines risks related to the project to determine the appropriate level of contingency needed. FTA will use a 65% probability threshold to determine reasonableness of the cost and schedule estimates.  


No.  Discounts on costs charged are not considered in-kind contributions and cannot be counted towards local match.  Discounts reduce the total project cost, which is used to calculate the federal and local shares.


FTA has been working closely with grantees in the storms’ aftermath and has utilized in-house staff and expert contractor support to help conduct and verify the damage assessments that form the basis for reimbursement requests.

To receive FTA ER funding, grantees must comply with ER program requirements as documented in the FTA Emergency Relief Program Final Rule and further explained in the Emergency Relief Manual, and must provide FTA with appropriate documentation in advance of any Federal funds being disbursed.

In addition to FTA’s standard oversight of grantees, FTA reserves the right to conduct more frequent and/or specific assessments as needed.


As with a waiver or modification request, an applicant may submit a preliminary application to and the appropriate FTA Regional Administrator.  An application is a short narrative that articulates the basic elements of the applicant's proposed use of PIPP and provides the basis for FTA to offer the applicant a preliminary assessment of the viability of potential experimental features. As the program matures and PIPP waivers or modifications are approved, FTA will also share with the applicant information about lessons learned from previous PIPP projects that may be relevant to the proposed project.


Even if funds have been appropriated or allocated to a New Starts, Small Starts, or Core Capacity project, FTA will not award a construction grant until the following conditions are met and FTA is assured the project is ready:

  • The project’s development and design have progressed to the point where its scope, cost, schedule, benefits, and impacts are considered firm and final;
  • All non-CIG capital funding for the project is committed;
  • All significant third party agreements are completed;
  • The project continues to obtain at least a Medium overall rating under the statutory evaluation criteria; and
  • The Project Management Plan and subplans have been updated to include a management approach at a sufficient level of development to construct and implement the project.

Yes. VW settlement funds can be used for local match. However, applicants must provide documentation that the funds have been reserved and can be used for the project.


As authorized by Congress, upon appropriation of Emergency Relief funds FTA has primary responsibility for reimbursing emergency response and recovery costs after an emergency or major disaster that affects public transportation systems. FTA works closely with FEMA and grantees to make sure that FTA ER funds do not go toward expenses that have already been reimbursed by any other Federal agency.


One request for a waiver or modification per phase of a project may be submitted, and a submission may include requests for waivers or modifications of more than one FTA requirement. Allowing a request for a waiver or modification for each phase of a project means a recipient may, for example, submit a request during the project development phase, a second request during the engineering phase, and a third request during construction.

FTA encourages applicants to include all requests for waiver or modification in one submission to streamline the waiver/modification request process.


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