Written Testimony regarding TIFIA eligibility criteria and offset of subsidy costs

Comment on Docket No. FHWA‐2009‐0123 regarding TIFIA eligibility criteria and offset of subsidy costs

This letter regards proposed changes to the USDOT’s programs created by the Transportation Infrastructure Finance and Innovation Act of 1998 (TIFIA). We support the proposed adjustments in weighting criteria and would shirt them further. We also support requirements to offset the subsidy cost of directly operating the program and the federal government’s risk‐insuring costs associated with the issuance of TIFIA credit. However, we are concerned that allowing applicants to pre‐pay for the federal government to mitigate or insure their financing risks may encourage and obscure excessive risk taking in the future. The comments address these three issues in turn.

Report

U.S. PIRG

This letter regards proposed changes to the USDOT’s programs created by the Transportation Infrastructure Finance and Innovation Act of 1998 (TIFIA). We support the proposed adjustments in weighting criteria and would shirt them further. We also support requirements to offset the subsidy cost of directly operating the program and the federal government’s risk‐insuring costs associated with the issuance of TIFIA credit. However, we are concerned that allowing applicants to pre‐pay for the federal government to mitigate or insure their financing risks may encourage and obscure excessive risk taking in the future. The comments address these three issues in turn.