| Comment Type | Total | |
| 1 | Proposal is too burdensome | 18 |
| 2 | Burden is understated | 7 |
| 3 | Additional burden may impact service | 12 |
| 4 | Reporting for 5310 should be at designated recipient, not subrecipient, level | 9 |
| 5 | Limit (or eliminate) 5310 reporting | 8 |
| 6 | Limit 5311 Reporting | 10 |
| 7 | Remove 5310 performance targets | 4 |
| 8 | Assets should be reported only if $50K or above | 10 |
| 9 | Inventory should not include contractor assets | 14 |
| 10 | Equipment should not be reported | 10 |
| 11 | Implementation should be postponed | 9 |
| 12 | Requirements should be consistent with TERM | 3 |
| 13 | Assets reported into NTD should not necessarily be subject to TAM requirements | 5 |
| 14 | Allow for bulk upload | 5 |
| 15 | Collaborate with industry to develop requirements | 2 |
| Total | 126 | |
| Respondent Type | Total | |
| Government Body (State DOT) | 10 | |
| Transit Provider | 10 | |
| Association/Union/Trade | 2 | |
| Regional Planning Association | 1 | |
| Unique Respondents | 23 |
| # | Organization | Organization Type | Last Name | First Name | Title | Comment Types | Comment Overview | Proposal is too burdensome | Burden is understated | Additional burden may impact service | Reporting for 5310 should be at designated recipient, not subrecipient, level | Limit (or eliminate) 5310 reporting | Limit 5311 Reporting | Remove 5310 performance targets | Assets should be reported only if $50K or above | Inventory should not include contractor assets | Equipment should not be reported | Implementation should be postponed | Requirements should be consistent with TERM | Assets reported into NTD should not necessarily be subject to TAM requirements | Allow for bulk upload | Collaborate with industry to develop requirements | Specific Question(s) | Contact Information (if available) | Phone Number | |
| 4 | LA Metro | Transit Provider | Longley | Denise | Deputy Executive Officer, Enterprise Transit Asset Management | Endorses the comments made by APTA. FTA should re-sequence the requirement of setting TAM performane goals to be lateer than the requiremnt for approval of useful life benchmarks in the NTD. Timing of reporting into the NTD conflicts with the 3 month window for reporting targets in the TAM rule. The 3 month window is too short; shoudl be extended to 6-12 months. | X | X | After TAM rule | One Gateway Plaza, Los Angeles, CA 90012-2952 | 213.922.7294 | longleyd@metro.net | ||||||||||||||
| 7 | SFMTA | Transit Provider | Reiskin | Edward | Director of Transportation | FTA should clearly specify if all assets used in the provision of public transportation are required to be reported to the NTD. FTA should define a minimum value for assets to be reported, such as $10K. Recommends that the definition point to GASB for establishing a threshold. Add an optional asset ID field to forms separate from the 'notes' field. Asset Inventory should be consistent with TERM to avoid duplicating work. All for bulk uploads. Clarify passenger facility reporting requirements. Define facility square footage. Facility condition assessment should be consistent with the TERM scale. Recommends adding asset value for all assets. | X | X | 1 South Van Ness Ave, 7th Floor, San Francisco, CA 94103 | 415.701.4330 (Darton Ito) | darton.ito@sfmta.com | |||||||||||||||
| 8 | SEPTA | Transit Provider | Implementation should occur in the 2017 reporting cycle. Recommends simplifying the A-50 form to include only 4 categories of guideway. Recommends adding "custom special work" to the A-55 to allow all assets to be reported. | Until FYX7 | 1234 Market Street, 10th Floor, Philadelphia, PA 19107-3780 | 215.580.7103 (Laura Zale) | ||||||||||||||||||||
| 10 | SamTrans | Transit Provider | Harvey | Chuck | Deputy CEO | Possible Duplicate | NTD reporting requirements should align with TAM plan development requirement - 2 years after the final TAM rule. Reporting burden is underestimated, especially for large agencies. Diverting resrouces to create a TAM plan and performance metrics may impact service. Requests that FTA refine estimates ande identify a source of funding for compliance. New NTD reporting system lengtehend the time it took to report. FTA shoudl ensure the system is working properly. Leased property should not be included in asset reporting. | X | X | X | X | Align with the TAM requirements - two years after the final rule | Clarify the $X0K minimum asset reporting. Is this based on original cost, net book value, market value or replacement cost? | 1250 San Carlos Ave, P.O. Box 3006, San Carlos, CA 94070-1306 | 650.508.6228 (April Chan) | ChanA@samtrans.com | ||||||||||
| 12 | AC Transit | Transit Provider | Hursh | Michael | General Manager | Burden is understated. Cost of developing and maintaining the data set required is more than estimated. Condition reporting should be consistent with TERM and more guidance is needed. Data labels and structure should be consistent between TERM and NTD. Requests clarification on the $10K asset value floor. Requests further guidance on ULBs that are not based on accounting depreciation standards. Provide bulk upload/better data input usability. | X | X | X | X | Requests clarification on the $X0K asset value floor: unit or total? Requests guidance on calculating ULBS that are not based on accounting depreciation standards. | 1600 Franklin St, Oakland, CA 94612 | 510.891.4753 | mhursh@actransit.org | ||||||||||||
| 14 | Caltrans DRMT | Transit Provider | Travis | Brian | Supports AASHTo's comments. Limit data requests for 5310 and 5311 recipients. Approach at the recipient level. Only assets above $50K. No additioal reporting burden for 5339 recipients. Do not include assets less than $50K, ULB less than 5 yrs, 5310 performance measures, 5310 financial or service data. Do not include condition assessments for contractor assets. | X | X | X | X | X | X | X | X | X | 1120 N St, Sacramento, CA 942874 | 916.654.8655 (Mark Codey) | brian.travis@dot.ca.gov | |||||||||
| 16 | MTA | Transit Provider | Cummings | Crystal | Deputy Director, Federal Affairs and Emergency Relief Funding | Administrative and cost burden is vastly understated. Updating MTA's inventory for 20 yrs needs assessment takes 9-12 months. This assessment is updated ever 5 years. More frequent updating is not necessary. Burden estimate does not take into account additional staff to comply with FTA requirements. FTA should collaborate with the industry to develop more useful data. Recommends using the HERS sampling approach. Particularly concerned with replacement cost requirements and needs additional clarity on reporting performance restrictions. Defer implementation until after final TAM rule. Additional guidance is needed on facility condition reporting. FTA should not be prescriptive in the use of TERM. Requests detail on the availability of a bulk upload feature. | X | X | After final TAM rule with a one year blanket extension | Would like additional information on schedule of completion | X | 2 Broadway, New York, NY 10004 | 212.878.7000 | |||||||||||||
| 17 | Caltrain | Transit Provider | Harvey | Chuck | Deputy CEO | Possible Duplicate | NTD reporting requirements should align with TAM plan development requirement - 2 years after the final TAM rule. Reporting burden is underestimated, especially for large agencies. Diverting resrouces to create a TAM plan and performance metrics may impact service. Requests that FTA refine estimates ande identify a source of funding for compliance. New NTD reporting system lengtehend the time it took to report. FTA shoudl ensure the system is working properly. Leased property should not be included in asset reporting. | X | X | X | X | Align with the TAM requirements - two years after the final rule | Clarify the $X0K minimum asset reporting. Is this based on original cost, net book value, market value or replacement cost? | 1250 San Carlos Ave, P.O. Box 3006, San Carlos, CA 94070-1306 | ||||||||||||
| 19 | Valley Transportation Authority | Transit Provider | Rensi | Marcella | Transportation Planning Manager | Condition assessments require considerably more effort than estimated by FTA. It is feasible to provide an annual estimate and an updated condition assessment every 2-3 years follwing a complete assessment. California requires a complete assessment of rail assets every three years. Available data may not allow for an annual slow zone metric. Additional guidance is needed on the performance measures and targets. It is duplicative and time consuming to double report shared assets. Concurs with the decision to remove replacement cost information. Data submission should be streamlined. Requests the ability to upload directly from TERM lite or regional inventory. Exclude 5310 and JARC from reporting. Requests additional clarity on the relationship between the A-50 and A-55. S-20 should be retired. Does not understand why age is not associate with track (only service years when new) as this may impact service restrictions. Requests old facility forms be retired to avoid duplicate reporting. | X | Condition assessment requires considerably more effort than estimated by FTA | Exempt 53X0 | X | Requests clarification on the relationship between the A-50 and A-55 | 3331 North First Street, San Jose, CA 95134-1927 | 408.321.5555 | |||||||||||||
| 20 | Metrolink | Transit Provider | Leahy | Arthur | Chief Executive Officer | Concerned about proposed requirement to expand reporting to assets that are not owned or maintained by SCRRA. It is not reasonable to report condition assessments or replacement costs for non-owned assests. Non-owned guideway/track should be reported at the summary level similar to the current NTD fixed guideway segements form. Condition assessements should not be required for non-owned passenger facilities. Need clarification on the condition assessment for admin/maintenance facilities. Reporting of service vehicles and condition assessments should be required for contracted service vehicles. A condition based measure should be used for track and guideway rather than a performance metric such as slow zones. FTA should allow flexibility in the performance measures. | Particularly impactful given FRA requirements that already exist | Should not be required to report on condition assessments or replacement costs |
| # | Organization | Organization Type | Last Name | First Name | Comment Types | Asset Inventory Comments | K. Expansion of capital asset reporting required by MAP-21 | Other Comments | Specific Question(s) | Contact Information (if available) |
| 2 | Individual | Individual | Peplow | Jim | Asset Inventory | Yes | On the Revenue Vehicle Inventory (A-70), I wanted to see a column that would allow me to enter which vehicles are represented by a particular row. This would be an open cell that would allow us to list the vehicle ID # (our agency one, not the RVI ID). | None | ||
| 10 | Metro Link | Transit Provider | DePallo | Michael | Various | Yes | Identified an issue with the ownership structure of their passenger stations (many are owned by the cities where they are located - current language would require the city to report these assets or they would go unreported). Recommends simplifying guideway types and 'special track work'. | One Gageway Plaza, Floor 12, Los Angeles, CA 90012 Phone: 213.452.0200 |
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| 11 | APTA | Association/Union/Trade | Melaniphy | Michael | Various | Yes | "The Proposed Capital Asset Reporting Requirements Presuppose the Results of Future Rulemaking and Are Unduly Burdensome." FTA must accommodate existing TAM plans (and allow them to continue) and phase in any new requirements. They should rely on the Oct 2012 Asset Management Guide as the representative consensus view and keep the requirements 'high level'. Finally, third party assets should be differentiated. | 1666 K Street, 11th Floor, Washington, DC 20006 Phone: 202.496.4800 |
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| 15 | CalACT | Association/Union/Trade | Montgomery | Jacklyn | Various | Yes | Expresses concern that these requirements proceed an NPRM and 'substantive' circular. FTA should continue outreach and technical assistance for agencies that do not have the systems or tools in place. Finally, FTA should identify other 'acceptable methodologies for identifying and assessing the condition and useful life of assets'. | Requests information on how to obtain the congressional report the FTA's Office of Civil Rights provides on serving passengers with disabilities. | 1010 Hurley Way, Suite 140, Sacrament, CA 95825 Phone: 916.920.8018 |
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| 19 | Anonymous 1 | Individual | Anonymous | Asset Inventory | Yes | Lists questions for consideration. No specific feedback. | ||||
| 30 | Hampton Roads Transit | Transit Provider | Barnaby | Catherine | Various | Yes | Seconds an MBTA comment that notes that the proposed categories do not mirror the F-20 form. Suggests that these should be consistent. Cautions that trying to standardize data across all modes may not be appropriate (i.e. form requests odometer reading from ferryboats, which do not have odometers). Finally, expresses concerns re. the ability to obtain information from 3rd party contractors. The assets may not be used exclusively for transit service (which could skew data) and private companies have expressed concerns over losing competitive edge by sharing this data. | |||
| 40 | samTrans | Transit Provider | Scanlon | Michael | Various | Yes | Felt that the proposed inventory module would 'create an undue burden' to their agency. Also expressed concern over additional reporting requirements after the TAM system is established. | 1250 San Carlos Ave, San Carlos, CA 94070 Phone: 650.508.6200 |
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| 45 | Monteray Salinas Transtit | Transit Provider | Sedoryk | Carl | Various | Yes | Suggests that reporting requirements should be deferred until the rulemaking is complete. They advocate a gradual approach to implementing the requirements. | One Ryan Ranch Rd, Monterey, CA 93940 Phone: 831.899.2558 |
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| 46 | Massachusetts Bay Transportation Authority | Transit Provider | Guptill | Robert | Asset Inventory | Yes | Notes that the proposed categories do not mirror the F-20 form. Expresses that their current SGR database should be able to provide most of the proposed NTD requirements. Seeks clarity on how agencies should calculate facility condition. | |||
| 47 | Central Contra Costa Transit Authority | Transit Provider | Ramacier | Rick | Various | Yes | Restates APTA's concerns and recommendations (verbatim) | 2477 Arnold Industrial Way, Concord, CA 94520 Phone: 925.676.1976 |
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| 51 | Metropolitan Transportation Authority | Transit Provider | Renek | Naomi | Various | Yes | Expresses concern that the NTD requirements 'dismiss the results of FTA's Asset Inventory Module Pilot Program'. Requests clarification on the intent behind collecting this level of detail and requests that FTA 'more carefully consider the industry recommendations'. Requests that information be requested at a high level and encourages FTA to consider an alternative approach that allows for asset information to be reported in a manner that is not prescriptive. It will be difficult and potentially costly for MTA to put their data into the requested format. MTA also proposes that only assets which are owned or leased by an agency should be included in the data. | 347 Madison Ave, New York, NY 10017 Phone: 212.878.7000 |
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| 54 | King County Metro | Transit Provider | Various | Yes | Metro will be able to provide asset inventory data by 2015 but expresses concern that the rest of the industry is unlikely to be in the same position. They recommend an extension of the deadline to 2016. Express the need for clarification on reporting categories for consistency. | |||||
| 58 | SEPTA | Transit Provider | Cullison | James | Various | Yes | Requests an extension to 2016. Expresses concern over square footage requirements (may not correlate to replacement costs and may be difficult to obtain from a legacy system). Suggests terminology changes for guideway and track modules. Also requests and extension to 2017 for guideway data. | |||
| 64 | Golden Gate Bridge, Highway and Transportation District | Transit Provider | Davenport | David | Various | Yes | Expresses that they should be able to provide asset data and 'do not expect the process to be too onerous' given the timeline. Requests flexibility in setting a minimum threshold for asset inclusion (remove items less than $10K). | ddavenport@goldengate.org Phone 415.257.4546 | ||
| 71 | Metropolitan Transportation Commission | Government Body | Richman | Anne | Various | Yes | Requirement should be deferred until after the rulemaking. Final requirements should ensure compatibility and consistency between all FTA systems (i.e. NTD and TERM). Requests a bulk import/export feature be added to NTD. | 101 Eighth Street, Oakland, CA 94607 Phone: 510.817.5700 |
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| 76 | Fayetteville Area System of Transit | Transit Provider | Legans | Sheri | Asset Inventory | Yes | Requests modification of data entry. Additional column in A-30. | 455 Grove Street, Fayettevill, NC 28301 | ||
| 79 | WMATA | Transit Provider | Sullivan | Regina | Various | Yes | Suggests that reporting requirements are premature and should wait until after a final asset management rule. WMATA disagrees with FTA's interpretation of MAP-21 and suggests that maintaining an asset inventory through NTD is redundant and unnecessary. Recommends that FTA continue to use sampling to estimate backlog. Finally, feels that the proposed data collection would be overly burdensome. | 600 5th Street NW, Washington, DC 20001 Phone: 202.962.1234 |
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| 80 | Lane Transit District | Transit Provider | Kilcoyne | Ronald | Various | Yes | Replacement costs would be too difficult to determine and keep consistent amongst agencies. | P.O. Box 7070, Springfield, OH 97475 Phone: 541.682.6100 |
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| Total Comments | 18 |
| File Type | application/vnd.openxmlformats-officedocument.spreadsheetml.sheet |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |