South West Transit Association
FTA Draft Circular MID-LIFE OVERHAULS
FTA has issued a draft circular implementing the bus and bus facilities program, as modified in MAP-21. This draft circular details FTA’s proposed guidance on the administration and grant application process for the bus program. Click the links below for the draft circular and the Federal Register Notice seeking comments on the draft circular, along with all comments submitted to date.
Comments are due by September 29.
As proposed in the draft circular, FTA would not allow transit agencies to use bus program funds for mid-life overhauls. Like we saw in a Buy America rulemaking a couple of years ago, FTA is differentiating between ‘rebuilds’ that add useful life to a vehicle (allowable under the draft) and ‘overhauls’ that get the vehicle to its useful life (NOT allowable under the draft). This dichotomy runs contrary to both longstanding practice – maintenance as a capital expense – and the concept of ‘state of good repair.’
Please review the draft circular and consider submitting comments to FTA if you will be impacted by this change in eligibility for mid-life overhauls. If you provide comment to FTA, please also considering sharing those comments with SWTA.
States
Arizona, Arkansas, Colorado, Kansas, Louisiana, New Mexico, Oklahoma, Texas