Proposed Updates to Third Party Contracting Circular

Ms. Veronica Vanterpool Deputy Administrator Federal Transit Administration 1200 New Jersey Ave SE Washington, DC 20590 Re: Request for Extension to Submit Comments on Notice of Availability of Proposed Circular Updates, Docket No. FTA-2024-0015 Dear Deputy Administrator Vanterpool: The American Public Transportation Association (APTA) represents a nearly $80 billion industry that directly employs 430,000 people and supports millions of private-sector jobs. Our 1,600 member organizations include some 370 transit agencies and 850 businesses that operate, manage, plan, build and finance public transportation across the United States. Nearly every aspect of their work involves federal funding from the FTA. Accordingly, they are directly impacted by changes to the Federal Transit Administration (FTA)'s Circular on Third-Party Contracting Guidance, FTA C 4220.1F. APTA applauds FTA's work to update Circular FTA C 4220.1F, as it has not been updated in almost 12 years. However, the timing for the release of the changes and the short duration for comments, has proven challenging for many members to adequately review and comment. Accordingly, APTA, on behalf of its member organizations, requests that the deadline for submission of comments be extended until January 17, 2025, to provide additional time for review and, if appropriate, submission of comments. Thank you for your consideration and support for public transportation in the United States Sincerely, Paul P. Skoutelas President and CEO