Low or No Emission Program Frequently Asked Questions
- Is preference given for non-attainment areas even though it is not required?
- Will projects that only request incremental costs be prioritized over projects that request the full amount?
- If we have already registered on Grants.gov for submission of other grants, do we need to re-register specifically for this application?
- Can an applicant submit multiple grant application packages?
- Where do you find the SF-424 Form? Where do you find the Supplemental Form?
- What is the character limit on the narrative sections of the supplemental form?
- Can I convert the supplemental form to a Word document and upload to Grants.gov?
- Is it possible or appropriate to attach signed support letters, resumes, and other documents as supplemental details to the application?
- 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?
- What is the recommended documentation for local match?
- When demonstrating the state of need for replacement buses, is it best to attach documentation or verbalize the status in the narrative?
- How will FTA evaluate Demonstration of Need for proposals for new or expanded facilities?
- If awarded, do funds need to be expended by a certain time?
- Are partial awards possible under this program or is it all or nothing?
- Can you explain what is meant by workforce development?
- Is workforce development related to low or no emission vehicles also at 85% FTA/15% Local match?
- Can credit from partners for payment of operating costs for transit service qualify as local match or portion of local match?
- Is there a maximum/minimum amount that can be requested?
- How should letters of support be addressed?
- Can a public agency partner with a private firm on a Low-No application and meet the competitive procurement requirement?
- Can multiple agencies partner together for a single application under Low-No?
- Should an applicant submit their application to the State in addition to the FTA? Will the States review the applications after they are submitted to the FTA?
- We are applying for buses, chargers, and maintenance shop improvements. Is each of these a separate project within the supplemental form?
- 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?
- We applied in 2016 and were unsuccessful. Can we discuss our 2016 application?
- If an application proposes the use of formula funds up to the cost of a conventional bus and Low-No funds for the incremental cost of a zero emission bus, would the use of formula funds require competitive procurement?
No, this is no longer a program requirement or selection criterion.
Will projects that only request incremental costs be prioritized over projects that request the full amount?
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.
If we have already registered on Grants.gov for submission of other grants, do we need to re-register specifically for this application?
No, if you have registered and are up to date you should be able to apply for these opportunities.
Yes, this is allowable. Projects will be evaluated on a project by project basis regardless of how they are submitted to grants.gov.
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.
The character limit for each response is 4,000 characters. If you have additional information you would like to provide, you may include it as a separate attachment and reference the attachment in the narrative response. Please note that attachments should be used to support the narrative responses and that information or documents not cited in the narrative may not be reviewed.
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.
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.
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?
An applicant can choose either option; however, we recommend separate submissions for multiple urban agencies.
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.
When demonstrating the state of need for replacement buses, is it best to attach documentation or verbalize the status in the narrative?
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.
FTA has defined the criteria for Demonstration of Need in the NOFO, including specific guidance for expansion projects.
Funds must be obligated within three fiscal years after the fiscal year the funds were made available. For example, if the funds were made available in the fall of 2017, the funds must be obligated by September 30, 2020.
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.
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.
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.
Can credit from partners for payment of operating costs for transit service qualify as local match or portion of local match?
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.
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.
For letters that require an official response, address the letter to the Acting 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.
Can a public agency partner with a private firm on a Low-No application and meet the competitive procurement requirement?
An eligible recipient may partner with other entities that will assist in implementing the project. If an application that includes a partnership is awarded, then the competition itself fulfills the competitive procurement requirement. This provision only applies to the Low-No Program. Please refer to the Eligible Applicants and Project Implementation Strategy sections in the NOFO for additional information.
States and other eligible applicants may submit consolidated proposals for projects in urbanized areas. Proposals may contain projects to be implemented by recipients or sub-recipients. If a single project proposal involves multiple providers, the proposal must include a detailed statement regarding the role of each provider in implementing the project.
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?
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 small 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.
We are applying for buses, chargers, and maintenance shop improvements. Is each of these a separate project within the supplemental form?
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, DFTA encourages applicants to identify how the project can be scaled.
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?
The state should submit separate proposals on behalf of its small urbanized and rural areas. Each agency should have its own SF-424 and supplemental form.
No. FTA cannot discuss specific applications once the debrief period ends. Agencies have 30 days to request a debrief once the selected projects are published in the Federal Register Notice (FRN). The FRN for the 2016 cycle was published on September 7, 2016. Debriefs were conducted from July 27, 2016, when the projects were announced, until mid-October 2016.
If an application proposes the use of formula funds up to the cost of a conventional bus and Low-No funds for the incremental cost of a zero emission bus, would the use of formula funds require competitive procurement?
The NOFO states applicants can request Low-No funds for the incremental cost of low-no buses over standard vehicles. Applicants may choose to combine formula and Low-No 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. The Low-No Program’s competitive selection process satisfies the requirement for a competitive procurement.
- What is the difference between a "direct" recipient and a "designated" recipient?
- Can a non-designated recipient apply separately?
- Is an airport authority eligible to receive funding? What about state universities?
- What is a local governmental authority?
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.
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.
Only designated recipients of FTA funds, states, local governmental authorities and Indian tribes are eligible to apply for funds. If you are unsure about whether you can apply for funding, please contact your FTA Regional Office or your state’s Department of Transportation.
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.
- Do "facilities" include transportation centers or just shops/yards?
- Can we use this grant to pay for an implementation study that looks into replacing diesel fleet with all-electric bus fleet?
- 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?
- 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?
- Does the vehicle need to pass Altoona first for Low-No?
- If an agency plans to lease zero-emission buses, are the operating costs (i.e. lease payments) eligible?
- Is installing solar panels to an existing facility eligible?
- Can school buses be purchased with Low-No funds?
- Are there any additional reporting requirements for electric bus projects?
- If we place an order prior to the award announcement and we are selected to receive funding, would we be eligible for reimbursement?
- Are studies eligible for funding?
- What administrative costs are eligible?
- Are remanufactured vehicles eligible for purchase under the Low-No Program?
Both types of projects are eligible under the Low-No Program. However, facilities projects must directly support low-no buses.
Can we use this grant to pay for an implementation study that looks into replacing diesel fleet with all-electric bus fleet?
The Low-No Program is 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.
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?
It depends on how it is related to the project. 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.
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?
CNG vehicles are eligible, but CNG-powered vehicles may not be rated as highly as other alternative fuel projects that have lower emission than CNG. Propane-powered vehicles are also eligible. 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).
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.
If an agency plans to lease zero-emission buses, are the operating costs (e.g. lease payments) eligible?
Lease payments are considered a capital expense and are eligible under the Low-No Program. If an applicant proposes a capital lease in the application, the grantee will be required to provide the local match as the time of each payment under the lease agreement. In the case of the Low-No program, local funds must comprise 15% of each lease payment.
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.
No. School buses are not eligible.
No. The only required reports are Federal Financial and Milestone 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.
If we place an order prior to the award announcement and we are selected to receive funding, would we be eligible for reimbursement?
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.
Planning studies are not eligible for Low-No funds. However, data collection and analysis directly related to the implementation of the proposed project is eligible.
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.
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 the Low-No Program, 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.