MDOT is strongly opposed to combining all of the performance measure related and asset/ inventory reporting requirements into a single NTD reporting requirement for the Section 5310 program. Section 5310 NTD reporting should be narrow in scope and limited to data directly and exclusively related to the language in Section 5335(c), specifically “transit asset inventory and (if available) condition assessment conducted by the recipient.” All NTD reporting should be rolled up at and reported as a total for each designated recipient. There are states with over 100 subrecipients, many of which are not subject to NTD reporting now. MDOT believes FTA is underestimating the significant additional burden that will be placed on itself and its designated recipients to begin NTD reporting at the subrecipient level for the Section 5310 program.
Idea No. 74