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Frequently Asked Questions

These FAQs do not have the force and effect of law and are not meant to bind the public in any way. These FAQs are intended only to provide clarity to the public regarding existing requirements under the law or agency policies. FTA recipients and subrecipients should refer to FTA’s statutes and regulations for applicable requirements.

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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.

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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.
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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.

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Although there isn’t a page limit for supporting documentation, applicants should only include information that specifically supports the statements made in the narrative.  Applicants may include just the pertinent excerpts from a larger document.  For example, an applicant may attach a document that includes only the cover page and the pages referenced in the narrative. File sizes cannot be larger than 3 MB.

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Yes.  The spare ratio policy applies to all buses in an agency’s fleet.  However, FTA will permit agencies to include vehicles that have met their minimum useful life in their contingency fleet if the agency is introducing zero-emission vehicles into its fleet.  Contingency fleet vehicles are not included in the calculation of spare ratio.

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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.

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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.

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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).

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Yes.  FTA permits a single lump sum payment at the inception of the lease rather than periodic payments during the life of the lease.  Applicants requesting funds for a lump sum payment for a multi-year lease should discuss the strategy to ensure satisfactory continuing control of the battery in the application.  Once the award is made, the recipient must contact their FTA Regional Office to verify the information in the application.

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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.

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No. School buses are not eligible.

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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.

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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.

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HVIP vouchers can be used to satisfy the local match requirement.  Other state programs will be considered on a case-by-case basis.

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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.

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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.

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FTA has defined the criteria for Demonstration of Need in the NOFO, including specific guidance for expansion projects.

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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.

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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.

Answer:

Yes.  “Revenue service” means carrying passengers.  Fare-free transit is included in revenue service.  However, the service must be public transportation and open to all.

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