JUSTIFICATION STATEMENT

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DEPARTMENT OF TRANSPORTATION
FEDERAL TRANSIT ADMINISTRATION

JUSTIFICATION STATEMENT

National Transit Database

OMB Control No.2132-0008


ABSTRACT
This is an information request renewal to the Office of Management and Budget (OMB) to extend the information collection request (ICR) IC# 2132-0008, “National Transit Database” for three years. It is currently due to expire on August 31, 2026. FTA conducted a July 2025 Federal Register Notice to solicit comments on clarifications and reporting refinements for NTD report years 2025 and 2026. That notice validated that the administrative updates did not impact the respondent universe, reporting scope, or methodology. Consequently, the annual total burden remains unchanged from the 2023 previously approved burden hours of 456,179 hours. 

Purpose
The National Transit Database (NTD) was established by Congress to be the Nation’s primary source for information and statistics on the transit systems of the United States. Recipients of grants from the Federal Transit Administration (FTA) under the Urbanized Area Formula Funding Program (§5307) or Formula Grants for Rural Areas (§5311) are required by statute to submit data to the NTD. In addition, all recipients and subrecipients of 49 U.S.C. Chapter 53, Public Transportation (Chapter 53) funds who own, operate, or manage public transportation capital assets are required to develop and implement Transit Asset Management (TAM) plans. The NTD is designed to support local, state and regional planning efforts and help governments and other decision-makers make multi-year comparisons and perform trend analyses. It contains a wealth of information such as agency funding sources, inventories of vehicles and maintenance facilities, safety and security reports, measures of transit service provided and consumed, and data on transit employees. 

Justification

    1. Circumstances that make the collection of information necessary.

National Transit Database (NTD) system is a statutory requirement. 
49 U.S.C. 5335(a) requires the Secretary to “maintain a reporting system, using uniform categories to accumulate public transportation financial, operating, geographic service area coverage, and asset condition information and using a uniform system of accounts.” Additionally, 49 U.S.C. 5335(b) specifies that the Secretary may award grants under sections 5307 and 5311 “only if the applicant, and any person that will receive benefits directly from the grant, are subject to the reporting and uniform systems.” The NTD is the reporting system established to meet these requirements. By defining a national set of performance and financial metrics that are reported across the industry according to a standard set of rules, the NTD provides a common data vocabulary for evaluating and understanding public transportation issues.

Finally, 49 U.S.C. 5335(c) requires recipients of a grant to report “any information relating to a transit asset inventory or condition assessment conducted by the recipient, any data on assaults on transit workers of the recipients; and any data on fatalities that result from an impact with a bus.” Additionally, 49 U.S.C. 5326(c)(1) and (2) requires recipients to report annually on the condition of their transit assets as well as their progress against set performance targets. 


NTD data is used to report to Congress on the condition and performance of the nation’s transit systems. 

49 U.S.C. 308(e) requires the Secretary to report “on the current performance and conditions of public mass transportation systems.” This report is commonly referred to as the Conditions and Performance Report to Congress. The NTD is an essential source of this performance data, allowing FTA to report on overall ridership, transit capacity, and transit operating efficiency. The capital asset data collected through the NTD underpins the Transit Economic Requirements Model (TERM), which is used to estimate the nation’s transit investment needs for the next twenty years, a key component of this report. The asset inventory information improves the quality of the industry state of good repair analysis completed as part of this report. 

NTD data is used by multiple external stakeholders.

NTD data is used by State and local governments, as well as individual transit agencies, to conduct performance benchmarking among peer transit systems. NTD data is also frequently used by academic researchers seeking to improve public transportation systems. NTD data is a key component of the American Public Transportation Association’s Annual Factbook and data on capital assets. Time series of NTD data are frequently used by suppliers of transit equipment and services to evaluate market trends and by government at all levels to guide transit investment decisions. 

    2. How, by whom, and for what purpose the information is used? What are the consequences if the information is not collected?

How:
The NTD collects data through an online reporting system. Data is validated by analysts at the NTD operations center who work with the reporters to meet reporting requirements and specific data quality standards. The respondents using the NTD consist of large, urban transit systems, smaller and rural transit systems, federally-recognized Indian Tribes, as well as State and Territorial Departments of Transportation who enter data directly into the system on behalf of the transit systems in rural areas. Almost all of these reporters are recipients or beneficiaries of § 5307 or § 5311 grant funds. 

By Whom:

NTD data is used by FTA, Congress, State and local governments, academic institutions, individual transit agencies, and other public transportation stakeholders.

For What Purpose:

NTD data is used to understand the impacts of previous investments in public transportation and for performance benchmarking. NTD data is also used by FTA to apportion federal formula funds in accordance with statute. NTD data is also the only source of operating costs for various transit modes. All levels of government, from FTA to the state and local level, use this data to make public transportation investment decisions. This data would not be available from any other comprehensive nationwide source without the NTD. 

At the local level, NTD service and performance data are often used to make funding allocation decisions when multiple transit systems service the same area. State and local governments, as well as individual transit systems, use NTD information to make performance benchmark comparisons among peer groups of transit systems. Without NTD data, there would be no nationwide source for this sort of benchmarking, which would make it harder for transit managers to drive efficiency improvements in their own systems.

This supporting statement submission in ROCIS includes the 2026 NTD Policy. 

    3. Describe whether collection of information involves information technology and any consideration of using information technology to reduce the burden.

Data for the NTD is currently collected entirely using information technology. The NTD uses an online reporting system in which respondents enter data on their office computers. This data is checked for errors through a series of automatic validation checks and then through a visual review by a validation analyst. Information technology allows the automatic validation checks to quickly identify routine data-entry errors and allows the validation analyst to quickly raise more complex issues with reporters – and to quickly receive responses. From 1979 to 1994, NTD data were collected through paper forms, and from 1995 to 2001 NTD data were collected through diskettes that were mailed in. The online reporting system, in place since 2002, has significantly reduced the overall reporting burden from the paper-based and diskette-based processes. 

FTA leveraged the versatility of the Appian reporting system in formulating how it would collect transit data from the industry. Appian is a Platform as a Service (PaaS) that supports diverse collection methods with customizable features. Consequently, FTA uses both large forms and summary matrix data collection to reduce burden where possible. For instance, FTA proposed using annual matrix data collection in lieu of one-report-per-event for major events. This approach is much less time-consuming, and FTA leverages it for both assaults and bus fatality collision data collections.

    4. Describe efforts to identify duplication. 

The NTD is the only source of nationwide transit data and the only source of transit data collected according to a uniform system of accounts. Prior to the establishment of the NTD in 1979, the American Public Transit Association (APTA) collected and published financial and operating statistics based on reports from its members. This data set was limited since data was only collected from APTA members. Additionally, as a private membership organization, APTA had limited ability to validate these data, and there was no guarantee of public availability of these data. APTA has consistently supported the NTD as providing a valuable data resource for its members and for the general public. 

    5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

FTA continues to seek to reduce the overall burden of NTD reporting while maintaining the value of the NTD as a comprehensive nationwide data source. 

FTA has tiered reporting requirements to allow small urban and rural reporters to submit fewer forms to the NTD once a year. Additionally, rural NTD data is primarily collected through the State Departments of Transportation, which in many cases already has records of some of the required data, further minimizing the burden on small transit systems. 

    6. Describe consequences to federal program or policy activities if data were not collected or collected less frequently.
		
If data for the NTD were not collected, a number of FTA’s federal programs would be affected, including the Urbanized Area Formula Program, the State of Good Repair Formula Program, the Rural Formula Program, the Tribal Transit Formula Program, the Safety programs the National Transit Asset Management Program, FTA’s Program Oversight, and the Conditions and Performance Report to Congress. Updated data would not be available for use in the 5307 and 5311 formula apportionments, and approximately $20 billion in funds would be allocated by FTA on the basis of outdated data. This would frustrate the Congressional intent of using the formula programs to provide additional money to those areas that invest in public transportation. FTA’s safety programs such as the National Public Transportation Agency Safety Plan (PTASP), the State Safety Oversight (SSO) program and Special and General Directives would be without timely data on safety events at the Nation’s public transportation systems. NTD data would also not be available to FTA for reporting to Congress on the conditions and performance of the nation’s public transportation systems. FTA would not have current data for estimating the Nation’s public transportation state of good repair backlog. The absence of current NTD data could alo affect DOT wide data products that rely on NTD data, including products maintained by the Bureau of Transportation Statistics, such as the National Transportation Atlas Database (NTAD) which houses the National Transit Map (NTM) and National Transportation Statistics (NTS). Current NTD data also would no longer be available to FTA, State and local governments, researchers, and individual transit agencies for conducting peer group analyses and performance benchmarking activities to ensure that the nation’s transit systems are run efficiently and effectively.

    7. Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.6.

The NTD data collection is consistent with 5 CFR 1320.6.

    8. Describe efforts to consult with persons outside the agency to obtain their views.

FTA remains committed to implementing reasonable data reporting requirements that reflect public input wherever possible. FTA regularly engages with stakeholders such as public transit agencies, State Departments of Transportation, industry stakeholders, and other members of the public regarding NTD proposed changes for reporting requirements. For example, FTA uses its website, emails received from its NTD help desk, and comments received through the Administrative Procedure Act to engage with the public. 

In July 2025, FTA sought comment through notices in the Federal Register on how FTA would implement new reporting requirements while providing clarifications to existing requirements. As part of this public engagement effort, FTA validated that the  proposed changes would not result in an increase in burden over the current reporting requirements. FTA proposed existing standards where possible, including leveraging General Transit Feed Specifications (GTFS), expanding asset data collection, while also reducing burden where possible, including consolidating stations and facilities reporting. 

On March 26, 2026, FTA published a 60-day Federal Notice (91 FR 14751) to review this 
information collection renewal. Ten comments were received from this publication. FTA has attached the response to comments in the Public Comments section in ROCIS. FTA considered all the comments and suggestions provided and concluded that it will not make any changes to the information collections based on the comments before submitting the ICR to OMB for review. 

On August 20, 2026, FTA published a 30-day Federal Notice (91 FR 53933). 

    9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift is made to respondents.
	
    10. Describe any assurance of confidentiality provided by respondents.							
No assurances of confidentiality are made to respondents.

    11. Additional justification for any questions of a sensitive nature.

No sensitive information is requested or required.

    12. Estimates of the hour burden of the collection of information and annualized cost to respondents. 

NTD reporters are comprised of Rural, Urban, and Small/Tribal Transit Systems. 
	
Respondents: Rural, Urban, and Small/Tribal Transit Systems
Estimated Annual Number of Respondents: 2,481
Estimated Annual Burden Hours: 456,179 
Estimated Total Cost to Respondents: $26,380,862
Frequency: Annual





TABLE 1: Summary of Hours of Annual Burden Calculation

Reporting Component
Total Annual Hours
Rural Reporters
120,409
Reduced Reporters
27,464
Full Annual Report Hrs.
245,996
Miscellaneous 
29,024
Monthly Safety Reporting Hrs. (annual)
33,286
Total Annual Hours
456,179


TABLE 2: Cost of Annual NTD Reporting by Transit Providers

Item
Labor Category
(BLS code/title)
Business Operations Specialists, All Other (bls.gov)
Labor Rate ($/hrs.)
(May 2025 BLS Statistic including 28% fringe benefits)
Preparation Time (hrs.)
Cost 
($1,000s)
Urban Reporters
Business Operations Specialist (13-1199)
57.83
332,212
$19,211,820
Rural and Small Systems
Business Operations Specialist (13-1199)
57.83
123,967
$7,169,012
Total Annual Cost
456,179
$26,380,832

    13. Estimate of total annual cost burden to respondents or recordkeepers resulting from the collection of information (not including the cost of any hour burden shown in items 12 and 14).

There is no additional cost beyond that shown in item 12. 

    14. Estimate of annualized cost to the federal government. 

The NTD is supported by contractors and was updated in FY 2026 at a level of approximately $3.267 million. The NTD is also supported by 3 FTE at GS-13 step 5 (opm.gov) approximately $237,000 each for a total of $711,000 including a fringe benefit multiplier of 1.72. The NTD has additional administrative costs of approximately $2.3 million each year for IT equipment and support. 

Thus, the total cost to the federal government for FY26 for the NTD is $6,270,000.  

    15. Explain reasons for changes in burden, including the need for any increases.

This information collection request does reflect an increase in burden hours. There is an increase in cost to both the respondent and federal government because of updated median hourly wages listed by the Bureau of Labor Statistics (BLS) and the Office of Personnel Management (OPM). There are no changes in item 13. 

    16. Plans for tabulation and publication for collections of information whose results will be published.

Data from the NTD is made available electronically at www.ntd.fta.dot.gov. Data is published in various Microsoft Excel-format files and data.transporation.gov. Data from each transit system reporting to the NTD is also compiled into a summary one-page data profiles, which are published here: https://www.transit.dot.gov/ntd/transit-profiles-summary-reports. Other data compilations and analyses of a more ad-hoc nature are also posted on the FTA website.

    17. If seeking approval not to display the expiration date for OMB approval, explain the reasons.
The OMB control number is publicly published on the Federal Register Notice and also available on the FTA website.  Additionally, when respondents log into NTD, this information is displayed on the homepage of the site.

    18. Explain any exception to the certification statement identified in Item 19 of OMB Form 83-I.

There are no exceptions to certification statement.