The Metropolitan Transportation Commission (MTC) is the Metropolitan Planning Organization for the nine-county San Francisco Bay Area and the Designated Recipient for FTA Formula Funds for the large urbanized areas in our planning area. In refining how FTA defines or classifies a Federal Project, any potential changes should consider:
- Allowing project sponsors to more easily combine state-of-good-repair-type (SGR-type) project components into larger capacity expansion projects to allow Section 5337-SGR and 5309-CIG funds to both be used on the project. Many expansion projects also serve to improve state of good repair. For example, new railcars or upgraded traction power systems procured as part of a capacity expansion project may also replace old railcars and power substations that are past their useful life. The definition of Core Capacity projects should recognize this reality, and project components that serve both capacity expansion and state of good repair purposes should remain eligible for both Section 5309 CIG funds and Section 5337 SGR funds; and
- Allowing project sponsors with CIG-funded infrastructure programs to separate out the component projects that are not federal, but still integral to the overall program to have FTA regulations and requirements apply only to the projects within the larger program that are federally-funded. However, the contribution of non-federal components to meeting the goals of the program, such as increased ridership or capacity, should still count in FTA’s rating of the project against the statutory criteria for CIG funding.
In both of these cases, MTC’s comments are focused on relieving projects from FTA regulations and requirements. These potential changes could help to expedite project delivery and lower costs. For example, allowing 5337 and 5309 funds to be used for the same overall project/program to both expand capacity and replaced aging assets would make more funding available for these critical needs.