Coalition Letter to Federal Transit Administration on Buy America Minivan Request

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Ms. Veronica Vanterpool
Acting Administrator
Federal Transit Administration
1200 New Jersey Avenue, SE
Washington, DC 20590-0001

Re: Extension of FTA Partial Buy America Waiver for Minivans and Vans (Docket No. FTA-2022-0013)

Dear Acting Administrator Vanterpool,

On behalf of Commute with Enterprise, the Community Transportation Association of America (CTAA), the Association for Commuter Transportation (ACT) and the American Public Transportation Association (APTA), we write concerning the current "Partial Buy America Waiver for Minivans and Vans" (Docket No. FTA-2022-0013). In various ways, the undersigned represent more than 90 public agencies around the nation that provides critical commuter vanpool services every day to working men and women who depend on these services. For the reasons outlined below, we respectfully request an extension of this waiver.

The current Buy America waiver, which extended previously approved waivers, expires October 25, 2024, less than three months from now. Since the waiver was granted, there has been no change in the marketplace and the market remains without a readily available Buy America-eligible vehicle in the minivan class (which includes eligible SUVs), nor is there an expectation that such vehicles will be available in the market in the near future.

FTA 2022-0013 is an extension of previous waivers. When the last waiver (FTA-2016-0025) expired in 2019, there was nearly a three-year gap between when that waiver expired and the new waiver (FTA-2022-0013) was granted. The lapse of a waiver had a significant impact on public transit agencies' ability to create and expand vanpool services that are critical to providing job access in both urban and rural areas during and in response to COVID.

We write to you in hopes of avoiding a similar lapse in the existing waiver. The current waiver is predicated on a lack of available qualified vehicles, and nothing has changed in the marketplace that would change this status. On behalf of the undersigned and the agencies we work with and represent, we request that the Federal Transit Administration extend the existing waiver for no less than four years or until such time as a readily available vehicle is on the market.

Commuter vanpooling is an effective and highly utilized way to provide public transit options in urban, suburban, and rural settings. Vanpooling is one of the fastest growing modes of public transportation and provides critical services each day - amounting to 731 million passenger miles of service in FY22. A lapse in a Buy America waiver would impact those riders by taking away their means of access to and from work and restrict the ability of transit agencies to expand options.

If you have any questions or would like more details, please contact the following from each organization and we will respond as quickly as we can - for Commute with Enterprise: [email protected], for CTAA: [email protected], for ACT: [email protected], for APTA: [email protected]. Thank you and everyone at FTA for the work you do, and we look forward to hearing from you.

Scott Bogren, Executive Director of CTAA

Mike Mangan, Vice President of Commute with Enterprise

David Straus, Executive Director of ACT

Paul Skoutelas, President & CEO of APTA

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