APTA Sends USDOT Comments on Proposed P3 VfM Guidance
1/2/2025
APTA sent USDOT comments on Dec. 31 on the proposed guidance for public-private partnership (P3) projects seeking credit assistance through the Transportation Infrastructure Finance and Innovation Act of 1998 (TIFIA) and Railroad Rehabilitation and Improvement Financing (RRIF) programs published in the Federal Register on Nov. 13, 2024, at 89 FR 89692.
APTA noted that P3’s “are a vital mechanism to align public and private interests and to deliver innovative and efficient projects.” APTA added that it greatly appreciates the Build America Bureau’s (BAB) efforts to ensure P3’s, including those related to transportation infrastructure projects, have access to innovative finance tools such as RRIF and TIFIA. “Having discussed the proposed guidance and the two additional matters on which BAB is seeking input with APTA’s diverse membership, including members who have firsthand experience with the TIFIA and RRIF programs, P3’s, and Value for Money (VfM) analyses,” APTA said it ”is concerned that the proposed guidance on P3 project delivery including VfM analyses would present an obstacle for public transportation-related P3’s to apply for TIFIA and RRIF credit assistance due to such projects’ unique timeline and life cycle.”
APTA urged BAB to alter the proposed guidance such that public transportation-related P3 projects receive a different schedule for VfM analyses that better reflects such projects’ unique timeline and life cycles. In addition, APTA proposed only requiring a VfM analysis for projects with costs exceeding $750 million if the user fees associated with the project result in net revenue generation. Finally, APTA recognizes that some projects could benefit from providing additional information beyond what is required in the IIJA for VfM analyses but urges DOT to not place additional requirements for all project sponsors completing VfM analyses.