Comment from Persistence Analytics Group LLC

Comment on FTA-2026-0201 National Transit Asset Management System Persistence Analytics Group LLC / United Grid submits this comment regarding FTA’s information collection for the National Transit Asset Management System. PAG / United Grid supports the purpose of the National Transit Asset Management system: helping transit agencies monitor and manage capital assets, assess condition, set performance targets, prioritize investment, and maintain a State of Good Repair. However, the value of the TAM system should not be judged only by whether agencies submit asset inventories, condition ratings, performance targets, and investment priorities. It should be judged by whether those submissions reveal whether the assumptions behind transit capital planning are holding over time. Transit asset management is fundamentally an assumption-integrity problem: What assets exist? What condition are they truly in? What useful life is being assumed? What maintenance cycle is being relied upon? What replacement cost is expected? What service risk emerges if the assumption fails? What federal, state, local, rider, or taxpayer exposure hardens around incomplete data? FTA should use this information collection to strengthen the evidence standard behind transit capital decisions. PAG / United Grid recommends that FTA ensure TAM reporting captures or supports the following: 1. Asset-life assumption integrity Agencies should identify the useful-life assumptions used for major assets and whether observed performance confirms or weakens those assumptions. 2. Maintenance and replacement-cycle risk Condition ratings should be linked to expected maintenance needs, replacement timing, service risk, and funding exposure. 3. Deferred maintenance visibility TAM reporting should help distinguish routine asset condition from accumulating deferred maintenance risk that may create larger future public-cost exposure. 4. Investment-priority evidence Investment priorities should be supported by condition data, safety risk, service criticality, lifecycle cost, and consequences of delay. 5. Performance-target accountability Annual targets should not become paper compliance. FTA should evaluate whether agencies meet, miss, revise, or defer targets, and why. 6. Group TAM plan transparency Where Tier II providers participate in group TAM plans, FTA should ensure that aggregation does not obscure asset-specific risk, local service vulnerability, or underinvestment. 7. Federal funding decision quality Because TAM data inform federal funding decisions and public transparency, the data should be reliable enough to support capital allocation, oversight, and lifecycle accountability. 8. Post-investment verification FTA should encourage agencies to compare expected asset outcomes with actual performance after investment, including whether rehabilitation, replacement, or procurement assumptions proved accurate. The broader principle is simple: A transit asset management system should not only inventory assets. It should verify whether the assumptions behind public infrastructure investment are durable, evidence-supported, and accountable. Public transportation depends on long-lived assets, long-term funding obligations, safety performance, rider reliability, and public trust. Weak asset-life or condition assumptions can lead to deferred maintenance, service disruption, safety risk, stranded capital, and higher future taxpayer or rider exposure. FTA should continue the TAM collection, but strengthen its practical utility by ensuring that asset condition data are connected to useful life, maintenance cycles, investment prioritization, public-cost exposure, and post-investment verification. State of Good Repair should mean more than reported condition. It should mean decision-grade evidence that transit assets, funding plans, and service obligations can hold over time. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/