APTA Provides Comments to FTA CIG Program RFI
9/22/2025
APTA submitted comments to FTA, Sept. 18, on how to improve the Capital Investment Grants (CIG) program, in response to a Request for Information (RFI) published in the Federal Register Aug. 19, 2025.
APTA’s responses to the questions posed in the RFI are as follows:
- FTA’s Economic Development and Land Use criteria feature multiple measures and sub-measures; in the spirit of program streamlining, APTA offers that adding additional factors to the project evaluation and rating process is unfavorable unless it is necessary to accomplish policy goals.
- APTA agrees that FTA should increase the weight given to transit-oriented development (TOD). The ability of CIG projects to successfully transform their surrounding land uses and leverage private investment is an important aspect of these public transit investments. This could be accomplished by elevating the specific Performance of Transit Supportive Plans and Policies evaluation sub-factor (which is currently one of five sub-factors under the Economic Development criterion’s Performance and Impacts measure) to equal the weight of the other three existing measures (i.e., establishing four measures weighted 25 percent each).
- APTA recommends that FTA captures opportunity zones within the Economic Development criterion. APTA believes that this would significantly contribute to aligning public investment in transit with private investment in opportunity zones. States designate opportunity zones in undercapitalized areas to attract investors, who receive tax credits for their investment. Leveraging these credited developments with high-capacity transit investments is a win-win proposition for opportunity zone residents and families.
In addition, APTA proposes the following recommendations and measures:
- Eliminate the Essential Services Land Use Measure.
- Warrant the Streamlined Financial Plan or Expedited Project Delivery Pilot Program for qualifying New Start and Core Capacity Projects.
- Provide Blanket Pre-Award Authority upon Completion of NEPA and Medium Rating.
- Implement the Expedited Technical Capacity Review Process.
- Clarify and Standardize the Sequence of Steps/Requirements (“Roadmap”) to Enter into Engineering and Execute a Grant.
To help achieve better operating plans that can produce more reliable forecasts, APTA proposes the following suggested actions. These will: (a) improve the realism of project service plans, and (b) better represent the existing transit network for use in Simplified Trips on Project Software (STOPS) model forecasts:
- Standardize Better Model and Reporting Documentation (i.e., Forecast Basis of Estimate (BoE).
- Publish an FTA “Empirical Priors” Library.
- Background Network Transparency/Better GTFS. Using GTFS that does not represent a service provider’s actual performance risks distorting forecasts. To capture these variables, project sponsors should be able to modify or adapt the background service plan GTFS using simple tools.
- STOPS/Region Cross-Checks. In addition to project sponsor runs, we recommend FTA produce a standardized STOPS run with the Service Envelope and FTA priors to flag outlier sensitivities.