Low-No and Buses and Bus Facilities FAQs
Q: Is the 5 percent dedicated to workforce development activities based on the Federal requested amount or the total project budget?
A: The percentage dedicated to workforce development activities is based on the Federal requested amount, not the total project budget.
Q: How do I determine the amount of funding required for workforce development?
A: For applicants proposing projects related to zero-emission vehicles for either program, 5 percent of the requested Federal award must be used for workforce development activities. For example, if the Federal request (not including any local share) for vehicles is $3,000,000, then divide that by 0.95 to obtain a total Federal request of $3,157,895 (please round up to the nearest whole dollar); of which $157,895 must be dedicated to workforce development activities.
The Federal versus local match for workforce development training is 80% Federal and 20% local match. One way to determine the amount of local share required for workforce development activities is to multiply the Federal requested amount by 0.25. Continuing with the example from above, $157,895 x .25 = $39,474 (please round up to the nearest whole dollar). This leads to a total workforce development budget of $197,369 ($157,895 in Federal request + $39,474 in local match).
Q: Will projects that only request incremental costs be prioritized over projects that request the full amount?
A: Projects to fund the incremental costs of a project may receive a higher rating for the local financial commitment to the project, but will still be evaluated based on the remainder of the evaluation criteria provided in the NOFO.
Q: If we have already registered on Grants.gov for submission of other grants, do we need to re-register specifically for this application?
A: No, if you have registered and are up to date you should be able to apply for these opportunities.
Q: Can an applicant submit multiple grant application packages?
A: Yes, this is allowable. Projects will be evaluated on a project by project basis regardless of how they are submitted to grants.gov.
Q: Where do you find the SF-424 Form? Where do you find the Supplemental Form?
Both the SF-424 and Program Supplemental forms can be downloaded from Grants.gov under the program opportunity tab. The supplemental form is also available from the FTA website at www.transit.dot.gov/funding/grants/lowno.
Q: Can I convert the supplemental form to a Word document and upload to Grants.gov?
A: An applicant must use the pdf supplemental form that is provided at Grants.gov or on FTA’s website. Other formats will not be accepted.
Q: Is it possible or appropriate to attach signed support letters, resumes, and other documents as supplemental details to the application?
Grants.gov will allow you to upload supporting documents. Supporting documents may be helpful to reviewers, as they may confirm what is stated in the narrative.
Q: I am a designated recipient and will be applying for multiple urban agencies. Should I use multiple SF 424s or just one SF 424 with multiple supplemental forms?
A: An applicant can choose either option; however, we recommend separate submissions for multiple urban agencies.
Q: What is the recommended documentation for local match?
A: 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.
Q: When demonstrating the state of need for replacement buses, is it best to attach documentation or verbalize the status in the narrative?
A: The narrative should provide a complete explanation of the need for replacement buses, including any relevant supporting information. Attachments, such as a fleet inventory, vehicle status report, or other documentation, may be used to support the statements in the narrative response.
Q: If awarded, do funds need to be expended by a certain time?
A: Funds must be obligated within three fiscal years after the fiscal year that project selections are announced. For example, project selections announced in June of 2021 must be obligated in a grant by September 30, 2024.
Q: Are partial awards possible under this program or is it all or nothing?
A: Applicants may provide a scalable option within their submission. FTA may award an amount that is less than the amount requested, provided that it will fund a project of independent utility.
Q: Can you explain what is meant by workforce development?
A: Workforce development includes activities related to employment or education with a direct linkage to the capital project. Examples include developing apprenticeships, on-the-job training, and instructional training for public transportation maintenance and operations occupations. Refer to FTA’s website for additional information.
Q: Is workforce development related to low or no emission vehicles also at 85% FTA/15% Local match?
A: Although the match for Low-No projects is 85% federal, 15% local match, workforce development match for CAA and ADA projects is still 80% federal, 20% local.
Q: Can credit from partners for payment of operating costs for transit service qualify as local match or portion of local match?
A: 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. Certain Federal funds may also be available for local match. Please see the CCAM Federal Fund Braiding Guide | FTA (dot.gov) for more information.
Q: Is there a maximum/minimum amount that can be requested?
A: There is no minimum or maximum application amount. Depending on the applications received, FTA may cap awards at a particular amount to ensure a diversity of funded projects.
Q: How should letters of support be addressed?
A: For letters that require an official response, address the letter to the Administrator at Federal Transit Administration 1200 New Jersey Ave., SE Washington, DC 20590. For letters that you wish to have considered as a part of the application, address the letters to the FTA Program Manager.
Q: Can a public agency partner with a private firm on a Low-No or Buses and Bus Facilities Competitive application and meet the competitive procurement requirement?
A: An applicant proposing a low or no emission project under both the Buses and Bus Facilities Program and the Low-No Program, or an applicant proposing only a low or no emission project under the Low-No program, may include partnerships with other entities that intend to participate in the implementation of the project, including, but not limited to, specific vehicle manufacturers, equipment vendors, owners or operators of related facilities, or project consultants. If an application that includes a partnership is awarded, then the competition itself fulfills the competitive procurement requirement. Please refer to the Eligible Applicants and Project Implementation Strategy sections in the NOFO for additional information.
Q: Can multiple agencies partner together for a single application?
A: Applicants are able to partner with other agencies. Each application can have only one lead agency who will be the grant recipient. All other entities would then be a subrecipient to that agency. The recipient is also responsible for ensuring that all subrecipients named in the application adhere to the federal and program requirements. Please note, both the recipient and subrecipient(s) must be eligible applicants.
Q: Should an applicant submit his/her application to the state in addition to the FTA? Will states review the applications after they are submitted to the FTA?
A: If an applicant is a direct recipient of FTA funds, then the application should be submitted to the FTA directly. States may only apply on behalf of rural and urbanized areas. States do not review the applications once they are submitted to FTA. If selected, the project will need to be added to the Statewide Transportation Improvement Program in cooperation with the MPO and/or state DOT.
Q: We are applying for buses, chargers, and maintenance shop improvements. Is each of these a separate project within the supplemental form?
A: Yes. Each can be considered a separate project. However, it is up to the applicant whether to present multiple related activities as a single project or as multiple independent projects. For projects with multiple components, FTA encourages applicants to identify how the project can be scaled.
Q: Since states can submit a consolidated proposal of behalf of both urbanized and rural areas, does the state have to submit separate consolidated proposals or can there be one single proposal including both urbanized and rural area projects?
A: The state may submit separate proposals on behalf of subrecipients or it may submit a consolidated proposal.
Q: If an application proposes the use of formula funds up to the cost of a conventional bus and Low-No or Bus Competitive funds for the incremental cost of a zero emission bus, would the use of formula funds require competitive procurement?
A: The NOFO states applicants can request Low-No or Bus Competitive funds for the incremental cost of low-no buses over standard vehicles. Applicants may choose to combine formula and Low-No or Bus Competitive funding. If an applicant chooses to include formula funding in an application that includes a partnership, the applicant will not have to go through the competitive procurement process if the project is submitted to both the Low-No and Bus Competitive Program or just the Low-No Program. The competitive selection process satisfies the requirement for a competitive procurement.
Eligible Applicants
Q: What is the difference between a "direct" recipient and a "designated" recipient?
A: Direct recipients receive funding directly from FTA. Designated recipients have been designated by the state governor or his/her designee to receive and/or sub-allocate. Both direct and designated recipients are eligible to apply directly for the Low-No program.
Q: Can a non-designated recipient apply separately?
A: Eligible applicants include designated recipients, states, local governmental authorities, and Indian tribes. Eligible subrecipients may partner with eligible recipients but cannot be the primary applicant.
Q: Is an airport authority eligible to receive funding? What about state universities?
A: Only designated recipients of FTA funds, states, local governmental authorities and Indian tribes are eligible to apply for funds. Airports that only provide transportation services on airport property are not eligible. State universities that provide public transportation service that is open to the general public are eligible. If you are unsure about whether you can apply for funding, please contact your FTA Regional Office or your state’s Department of Transportation.
Q: What is a local governmental authority?
A: A local government authority includes: (1) a political subdivision of a state, (2) an authority of at least one state or political subdivision of a state, (3) an Indian tribe, or (4) a public corporation, board, or commission established under the laws of a state.
Eligible Projects
Q: Do "facilities" include transportation centers or just shops/yards?
A: Both types of projects are eligible under the Low-No Program and Bus Competitive Program. However, for the Low-No Program, facilities projects must directly support low-no buses.
Q: Can we use this grant to pay for an implementation study that looks into replacing diesel fleet with all-electric bus fleet?
A: No. Both the Low-No and Bus Competitive Programs are for capital projects only. Studies and planning efforts are not eligible expenses. However, a project proposal may include project administration costs directly related to the deployment of eligible vehicles in revenue service.
Q: Eligible projects appear to be capital items only, however, we have a consultant who is interested in partnering with us to provide data services. Is data collection and analysis eligible?
A: Both the Low-No and Bus Competitive Programs are for capital projects only. Data collection could qualify as incidental project management expenses associated with a Low-No partnership. Applicants would need to define how these expenses are a part of the project implementation strategy and are directly associated with acquiring these vehicles and deploying them in regular service.
Q: Are CNG powered buses and facilities eligible? What about propane powered or hybrid buses?
A: CNG and propane-powered vehicles and hybrid vehicles are eligible and are considered low emission vehicles. For the Low-No Program, proposed vehicles must make greater reductions in energy consumption and harmful emissions, including direct carbon emissions, than comparable standard buses or other low or no emission buses (49 USC 5339(c)(5)(A). The Bipartisan Infrastructure Law requires that at least 25% of Low-No funding be awarded to low emission vehicles. For the Bus Competitive Program, all vehicles used in the provision of public transportation services, regardless of propulsion type, are eligible for funding. Please refer to Eligible Projects section in the NOFO.
Q: Can CNG powered buses and facilities be competitive in this process, or is it likely only electric or fuel cell projects will be selected? Is liquid propane eligible or is it the same as CNG?
The Bipartisan Infrastructure Law requires that at least 25% of Low-No funding be awarded to low emission vehicles. Please refer to Eligible Projects section in the NOFO. Proposed vehicles must make greater reductions in energy consumption and harmful emissions, including direct carbon emissions, than comparable standard buses or other low or no emission buses (49 USC 5339(c)(5)(A).
Q: Does the vehicle need to pass Altoona first for Low-No?
A: All vehicles must complete Altoona testing prior to receiving FTA funds. Applicants should specify whether their intended bus models have already completed testing, and if not, provide a proposed timeline for completing FTA’s Bus Testing requirements and provide assurance that the proposed model will successfully complete testing prior to deployment. This information should be included in the Project Implementation Strategy section. In no case will FTA reimburse an agency for costs associated with vehicles that have not completed testing.
Q: If an agency plans to lease zero-emission buses, are the operating costs (e.g. lease payments) eligible?
A: Lease payments are considered a capital expense and are eligible under both the Low-No and Bus Competitive Program. If an applicant proposes a capital lease in the application, the grantee will be required to provide the local match at the time of each payment under the lease agreement. Local funds must comprise 15% of each lease payment.
Q: Is installing solar panels to an existing facility eligible?
A: For the Low-No Program, funds cannot be used to retrofit an existing facility with solar panels unless the panels are necessary for the operation of electric vehicles. An agency can use Low-No funds to build a maintenance facility that uses solar panels if the facility is incidental to the operation of electric vehicles. For the Bus Competitive Program, solar panels can be incorporated in a facility project to power the building or other resources without a direct connection to the operations of the low or no emission vehicles within the fleet.
Q: Can school buses be purchased with Low-No or Bus Competitive funds?
A: No. School buses are not eligible.
Q: Are there any additional reporting requirements for electric bus projects?
A: No. The only required reports are Federal Financial and Milestone Progress Reports. These reports are submitted electronically using FTA’s electronic grants management system. FTA encourages recipients to continually evaluate performance of electric vehicles and to share information on their operation and performance within the transit industry.
Q: If we place an order prior to the award announcement and we are selected to receive funding, would we be eligible for reimbursement?
A: Pre-award authority starts on the day the projects are announced. Projects will not be eligible for grant reimbursement for expenses incurred prior to the date of announcement.
Q: What does FTA mean by cost already incurred and not allowable for reimbursement?
A: Low-No and Bus Competitive Program funds cannot be used to reimburse applicants for otherwise eligible expenses incurred prior to execution of a grant agreement unless FTA has issued pre-award authority for selected projects. Costs incurred on or after the pre-award authority date may be eligible for reimbursement. Pre-award authority starts on the day project selections are announced by FTA. Costs are considered incurred when a third-party contract is executed.
Q: Are studies eligible for funding?
A: Planning studies are not eligible for Low-No or Bus Competitive funds. However, data collection and analysis directly related to the implementation of the proposed project is eligible.
Q: What administrative costs are eligible?
A: Administrative costs must be directly related to implementing or overseeing a project. For examples of eligible administrative costs, refer to 2 CFR Part 225, Appendix B to Part 225 - Selected Items of Cost.
Q: Are remanufactured vehicles eligible for purchase under the Low-No or Bus Competitive Program?
A: Yes. Remanufactured vehicles are vehicles that have undergone substantial structural, mechanical or electrical rebuilding, restoration or updating by a third party and then are sold or leased to a transit agency. For the purposes of theses programs, remanufactured vehicles include vehicles that have been converted from a traditional power source to a low or no emission power source.
If an applicant includes remanufactured vehicles in the application, whether as a partnership with a remanufacturer or through a proposed competitive procurement, the application must address how the project will meet the remanufactured vehicle requirements identified in FTA Circular C.5010.1E --Award Management Requirements. This information should be addressed as a part of the project implementation plan and includes the following:
- Procurement. The recipient must identify in their application and procurement their intent to purchase previously-owned and/or remanufactured vehicles. As part of the bid or proposal the recipient must obtain certification and documentation ascertaining that applicable Bus Testing and Buy America requirements have been met by the original owner or remanufacturer.
- Useful Life. The grant application and procurement of a previously-owned vehicle must identify the applicable useful life for the vehicle.
- Bus Testing. The original vehicles must have met the Bus Testing Requirements in place at the time of acquisition by the original owner.
- Buy America. The original vehicles must have met the Buy America requirements in place at the time of acquisition by the original owner. Remanufactured vehicles must meet the applicable Buy America requirements for rolling stock for all new components and subcomponents added or replaced on the vehicle.
- DBE Requirements. When a remanufacturer responds to a solicitation for new, or remanufactured vehicles, with a vehicle that has post-production alterations or retro-fitting to provide a “like new” vehicle, the remanufacturer is considered a transit vehicle manufacturer and must comply with the DOT DBE regulations.
Q: Does our project need to be included in the TIP and STIP to be eligible for funding?
A: Yes. However, if the project is not in the TIP or the STIP, the proposal may state when the grant funds can be obligated and indicate the timeframe under which the TIP or STIP can be amended to include the proposed project.
Q: Can Low-No or Bus Competitive funds be used to fund preparation of a Zero-Emission Fleet Transition Plan?
A: No. Both the Low-No and Bus Competitive Program are for capital projects only and general studies or planning efforts are not eligible expenses. The cost of developing a transition plan is eligible under the planning programs (49 U.S.C. § 5305) as well as under the urbanized area formula (49 U.S.C. § 5307) and rural area formula programs (49 U.S.C. § 5311).
Q: Can a previously adopted Fleet Transition Plan be included in the application?
A: Yes. If the previously prepared or adopted Plan meets the requirements as stated in the Bipartisan Infrastructure Law (BIL), Pub. L. 117-58f, then it can be included in the application. Applicants can provide a Cover Letter or Addendum to provide information required by the BIL that is not included in the previously adopted Fleet Transition Plan.
Q: If a State is submitting a consolidated application for zero emission vehicles to the Bus Competitive or Low-No programs, is a statewide Fleet Transition Plan required?
A: Not necessarily. A State submitting a consolidated application for zero emission vehicles may submit a statewide Fleet Transition Plan, plans the State develops for each of the individual subrecipients included in the application, plans the subrecipients develop and provide to the State for inclusion in the application, or any combination of these three options.