Grant Intelligence for Transportation Professionals
ATP Intelligence Module — Active Transportation Program (Cycles 1–8)
8
Program Cycles (2014–2027)
$3.8B+
Total Funded (Cycles 1–7)
800+
Projects Funded Statewide
85%+
Funds to DACs Every Cycle
Jun 2026
Cycle 8 App Deadline
$1.07B
Cycle 6 Total (2023)
~$1.7B with SB1 boost · Largest cycle ever
$168M
Cycle 7 Total (2025)
Budget cuts → 4% funded · 13 projects only
$500M+
Cycle 8 Expected (2027)
~$275M statewide · $46M MTC region
$2.5B
Cycle 7 Requests
vs. $168M available → 15:1 oversubscribed
📈 Program Funding by Cycle — ATP Total ($M)

ATP funding has fluctuated dramatically by cycle, peaking at ~$1.7B in Cycle 6 due to a one-time $1.05B SB budget surplus augmentation. Cycle 7 was cut to $168M — the lowest since Cycle 2 — reflecting fiscal pressures. Cycle 8 is expected to return to ~$500M.

🥧 Fund Distribution — Three Components

ATP is split by statute: 50% Statewide (CTC-awarded), 10% Small Urban & Rural, and 40% MPO Component distributed by population to the 10 largest MPOs. Every component must direct ≥25% to disadvantaged communities and no more than 2% to plan projects.

🏛️ Who Wins ATP Funding? Applicant Types

Cities and counties dominate, but school districts, tribal governments, transit agencies, and nonprofits are all eligible. Tribal projects get full leveraging points automatically — no letter of commitment required.

📐 Project Type Mix — All Cycles

Infrastructure projects (sidewalks, bikeways, crosswalks, signals) dominate. Plan projects are capped at 2% of any component. Non-infrastructure must be new programs or new components of existing ones — continuation is ineligible.

💡 ATP vs. Other Programs — Strategic Context

🚲 California's Only Dedicated Active Transportation Fund

ATP is the sole statewide program exclusively for biking and walking infrastructure. Unlike HSIP or SS4A, there is no motor vehicle safety focus — projects must primarily benefit non-motorized users. This makes it the natural funding home for any bike/ped capital project with a clear active transportation benefit.

📊 Chronically Oversubscribed at 3:1 to 15:1

In Cycle 6, $3.1B in applications competed for $1.07B. In Cycle 7, $2.5B competed for $168M — a 15:1 ratio with only 4% of projects funded. Even in a well-funded cycle, a score of 89+ is typically required to win. This is California's most competitive transportation grant program by application volume.

🤝 Stacks Well with SS4A and HSIP

ATP infrastructure projects (sidewalks, bike lanes, crosswalks) pair naturally with SS4A safety countermeasures and HSIP safety-focused improvements. A jurisdiction can apply for the same corridor in multiple programs if the project elements are distinct. ATP for bike/ped infrastructure + SS4A for signal/crosswalk safety = complementary project bundles.

⚠️ Cycle 7 Was an Anomaly — Critical Context

Cycle 7 (2025 ATP) was funded at only $168M due to Governor Newsom's 2024 budget cuts — down from $1.07B in Cycle 6. Only 13 projects were funded statewide (9 statewide + 4 small urban/rural), all scoring 95+ points. This was the most competitive cycle in program history. Cycle 8 is expected to return to normal (~$500M), making it substantially more accessible.

🔄 All Cycles Summary — ATP Award History
🏆 Cycle 7 (2025) — Funded Projects: Statewide & Small Urban/Rural

Only projects scoring 95+ received funding. All 13 awarded projects directly benefit disadvantaged communities. Infrastructure was the dominant type — 5 of 9 statewide projects included Safe Routes to School components.

🌉 Cycle 7 (2025) — MPO Component

The MPO component ($67.5M across 10 MPOs) was adopted June 2025. Each MPO ran its own competitive process. MTC (Bay Area) had ~$49M; SACOG adopted $4.72M; SJCOG awarded $14.7M to 3 projects. Scores in the MPO component are typically lower than statewide (80s range).

📋 Cycle 6 (2023) — Program Summary & Notable Awards

Cycle 6 was the largest ATP cycle in program history, totaling ~$1.07B ($1.7B with MPO component), funded 67 projects in the statewide component (score threshold: 89+), and 134 MPO projects ($539M). The one-time $1.05B SB 1 augmentation enabled this unprecedented scale. All funds benefited DACs.

$1.07B
Cycle 6 Statewide + SUR
Adopted Dec 2022
$539M
Cycle 6 MPO Component
134 projects · Adopted Jun 2023
89+
Score Threshold (Cycle 6)
vs. 95+ in Cycle 7
Notable Cycle 6 Awards — Illustrative Examples
📊 Competitive Intensity — Score Thresholds by Cycle

The minimum score to receive funding has varied significantly by cycle and available budget. In Cycle 6 (high budget), projects scoring 89+ were funded. In Cycle 7 (deep budget cuts), only 95+ received funding. Cycle 8 at ~$500M is expected to fund projects in the 88–92 range based on historical patterns.

🎯 2027 ATP (Cycle 8) — Scoring Rubric by Application Type

All applications are scored out of 100 points. The rubric varies by application type — large infrastructure projects have additional criteria (Transformative, Context-Sensitive) that smaller projects do not. Corps Use can deduct up to 5 points; Past Performance can deduct up to 10 points.

Scoring Topic Large Infra
>$10M total
Medium Infra
$3.5M–$10M
Small Infra
≤$3.5M total
Plan Non-Infra
Only
Benefit to Disadvantaged Communities 10 10 10 30 10
Need 38 40 52 20 40
Safety 20 25 25 10
Public Participation & Planning 10 10 10 25 15
Scope + Cost Effectiveness 7
Scope + Plan Consistency 5 3 10
Context-Sensitive / Innovation Large & Medium only 5 5
Transformative Projects Large only 5
Evaluation & Sustainability 10
Leveraging Large & Medium only 5 5
Implementation & Plan Development 25
Corps Use (Deduction) Avoid -5 0 or −5 0 or −5 0 or −5 0 or −5
Past Performance (Deduction) Up to −10 0 to −10 0 to −10 0 to −10 0 to −10 0 to −10
TOTAL (before deductions) 100 100 100 100 100

🏗️ Large Project (>$10M total)

Extra scoring criteria: Transformative Projects (5 pts), Context-Sensitive Bikeways (5 pts), Scope/Cost Effectiveness (7 pts), Leveraging (5 pts). Randomized field reviews possible. CEO or authorized officer signature required.

🏘️ Medium Project ($3.5M–$10M total)

Context-Sensitive (5 pts), Leveraging (5 pts). No Transformative criterion. Must include construction application unless applying for pre-construction only. Most Bay Area city-scale projects fall here. Minimum $250K ATP request.

🏡 Small Project (≤$3.5M total)

No Leveraging or Context-Sensitive scoring. Simpler rubric. SRTS, non-infrastructure, recreational trail, and plan projects are exempt from the $250K minimum request. High success rate in properly funded cycles.

📌 Scoring Criteria Deep Dive — What Each Category Measures
A

Benefit to Disadvantaged Communities (10–30 pts)

Three subsections: direct benefit, project location, and severity. Also scores anti-displacement policies. Worth 10 pts for infrastructure, 30 pts for plans. Five DAC qualifiers: Median Income <$79,298 (ACS 2020-2024), CalEnviroScreen ≥40.05, 75%+ NSLP-eligible students, HPI ≤25th percentile, or Tribal Lands.

B

Need (38–52 pts for Infrastructure)

Highest-weighted criterion for infrastructure. Must demonstrate: connectivity to key destinations, transit access, everyday needs/services access, local public health concerns, and student active transportation needs. Need score considers children, older adults, persons with disabilities, and mobility device users specifically.

C

Safety (20–25 pts)

Must address fatality/serious injury reduction potential. Score considers: identified hazards, collision history, selected countermeasures, and whether the project location is a priority. Must demonstrate both that the location is a priority AND the project will remedy identified hazards.

D

Public Participation & Planning (10–25 pts)

Document specific outreach activities, evidence of engagement, and community feedback received. Large project applications score higher if the project is specifically listed in an adopted bicycle, pedestrian, SRTS, or active transportation plan (Section 891.2 compliant).

E

Corps Use (0 or −5 pts)

Applicants must consult California Conservation Corps AND local conservation corps for every application, every cycle — prior cycle consultation does not count. Failure to consult or intent not to use = −5 points. Submit via JotForm to both CCC and Local Corps.

ACTION ITEM: Consult Corps immediately — before application is due
⚠️ Past Performance Deductions & Screening Criteria

Past Performance — Up to −10 Points

CTC deducts up to 10 points for: non-use of Corps as committed in prior ATP award, adverse audit findings on past ATP projects, or failure to deliver ATP project phases from prior cycles. Agencies with outstanding corrective action plans should resolve them before applying.

Purposeful Misrepresentation = Disqualification

If CTC determines an applicant intentionally misrepresented information that could affect score, ALL applications from that applicant in the current AND subsequent cycle may be removed. This applies to inflated cost estimates, fabricated community support, or inaccurate DAC qualifications.

Screening Criteria (Pass/Fail — Applied Before Scoring)

Applications that fail screening are not evaluated. Key screening items: application complete per Guidelines, consistent with adopted RTP, all other funds committed, not supplanting committed funds, correct application type used, minimum funding request met ($250K general; no min for SRTS, NI, recreation trails, plans), not required as condition of private development, pre-construction phases also apply for construction funding.

Tiebreaker Priority Order

1) Project readiness (completed environmental docs) · 2) Highest score on highest point-value question · 3) Highest score on second-highest point-value question. Tiebreakers are used only at the funding cut-off score. Always target readiness as your tiebreaker advantage.

📋 Scoring Rubrics Released March 27, 2026

CTC published Cycle 8 scoring rubrics March 27, 2026. Use them! All evaluator teams must use the official rubric. Rubrics specify exact point allocations for each response quality level. Applications prepared against the rubric consistently outperform those that ignore it.

📊 Score Distribution Analysis — Cycles 6 & 7

Understanding how scores cluster helps calibrate expectations. In Cycle 6, the funded range was 89–100 with hundreds of applications in the 70–88 "unfunded but meritorious" band. In Cycle 7, the threshold jumped to 95+ due to budget cuts. Cycle 8 at ~$500M is expected to fund into the high 80s.

🏗️ Infrastructure Project Types That Win ATP

Based on Cycles 5–7 funded applications and the 2027 Guidelines (Appendix A). Infrastructure is the dominant funded category. Projects must have independent utility (standalone benefits), a complete PSR equivalent, and be consistent with a regional transportation plan.

🥇 TIER 1 — Core ATP Winners (Appear in Most Funded Projects)
These project types appear consistently across all funded infrastructure applications. Applications should anchor around multiple Tier 1 elements. All must improve mobility, access, or safety for non-motorized users.
Sidewalk Construction & Gap Closures ADA Curb Ramps & Accessible Paths High-Visibility Crosswalks Class I Multi-Use Paths / Trails Class II Bike Lanes Class IV Protected Bikeways Rapid Flashing Beacons (RRFB / HAWK) Safe Routes to School Infrastructure Pedestrian-Scale Lighting
🥈 TIER 2 — Strong Supporting Elements (Frequently Combined)
These elements frequently appear alongside Tier 1 projects, adding connectivity, safety, and usability. They score well under "Need" and "Safety" when data-supported.
Bicycle Highways (High-Speed Commuter Routes) Complete Low-Stress Bicycle Networks Safe Routes to Transit Connections Traffic Circles / Roundabouts (Pedestrian Safety) Protected Intersections Secure Bicycle Parking Wayfinding Signage Trail-Transit Connectivity Bike Share Infrastructure
🥉 TIER 3 — Specialized / Supplementary (Context-Dependent)
These elements are eligible and score well in appropriate contexts but are rarely the core of a winning application alone. Strong in combination with Tier 1/2 or in rural/tribal applications.
Recreational Trails (Trailhead Access, Rail-to-Trail) E-Bike Infrastructure (Charging, Parking) Preventive Maintenance (Bikeways with safety improvement goal) Ferry/Rail Bike-Carry Facilities Quick-Build Interim Improvements (MPO Only) Senior-Focused Active Transportation Routes
Project Characteristics That Score High

Located in or Adjacent to a Disadvantaged Community: Must directly serve a DAC (not just be nearby). Demonstrate direct, meaningful, assured benefit. Projects in CalEnviroScreen top 25% or Median HH Income <$79,298 automatically qualify.

Connectivity to Schools, Transit, and Essential Services: Projects connecting neighborhoods to schools, transit stops, medical facilities, grocery stores, and employment score significantly higher on "Need." Map all destinations within 1 mile of project.

Documented Crash History at Project Locations: Use SWITRS/TIMS 5-year collision data. Show pedestrian and bicyclist KSI patterns. Locations with documented fatalities or serious injuries score highest on "Safety."

Listed in an Adopted Active Transportation Plan: Large project applications score higher if specifically listed in an adopted bicycle plan, pedestrian plan, SRTS plan, or comprehensive active transportation plan per Section 891.2.

Robust Community Engagement Including Disadvantaged Voices: Document meetings, surveys, walk audits, flyers, multilingual outreach. Show feedback received AND how project design incorporates it. Engagement in the project-specific area, not general citywide surveys.

Committed Matching Funds (Though Not Required): While ATP does not require match, leveraged funds improve score on "Leveraging" (Large/Medium apps) and signal project strength. SB 1 LSRP funds are an excellent match source.

Anti-Displacement Policies and Actions: Explicitly required in the "Benefit to Disadvantaged Communities" score. Document any local anti-displacement ordinances, tenant protections, or affordable housing programs in the project area.

ATP Funding Restrictions — What Is NOT Eligible

New Sharrows on Roads >30 MPH: Expressly prohibited by Streets & Highways Code §891.9. Sharrows over 30 MPH require justification showing local context appropriateness and advancing low-stress network — reviewers scrutinize this heavily.

Class III Bikeways (Generally): Cannot fund new Class III unless: road is ≤25 MPH design speed, project reduces design speed to ≤25 MPH, or applicant demonstrates appropriateness for local community context advancing low-stress network.

Supplanting Other Committed Funds: A project already fully funded cannot receive ATP. ATP cannot replace committed funding already obligated to the project.

Cost Increases: ATP will not fund cost increases to already-programmed projects. Agency must absorb overruns. Exception only for Caltrans on-system projects (Supplemental process).

Ongoing/Existing NI Programs Without New Components: Non-infrastructure projects must be new programs or new components. You cannot use ATP to continue a program already operating — must demonstrate how ATP starts something new.

Pre-Construction Without Construction Application: If applying for PAED, PSE, or RW, you MUST also apply for construction funding in the same application. Exceptions exist only for Large Infrastructure pre-construction only and MPO supplemental applications.

Projects Required by Private Development: Mitigations required as conditions of private development approvals or permits are ineligible. Screened out before scoring.

📋 Expert Playbook — Maximizing Your ATP Cycle 8 Score
STRATEGIC FOUNDATION
1

Lead with "Need" — Not Just Safety

Unlike SS4A which is safety-first, ATP's highest-weighted criterion for infrastructure is "Need" (38–52 pts). Open with connectivity data: how many people currently lack access to transit, schools, medical facilities, or employment by walking or biking? Combine origin-destination analysis, land use maps, and community survey data to build a compelling need narrative. Need score requires demonstrating student active transportation needs explicitly.

TIP: Use SACOG's ATP Data Mapping Tool to identify connectivity gaps in your jurisdiction
2

DAC Documentation Is Non-Negotiable

Every funded project must demonstrate direct, meaningful, assured benefit to a disadvantaged community — even if it's within one. The CTC warns: "there is no presumption of benefit, even for projects located within a disadvantaged community." Map your CalEnviroScreen scores, ACS income data, and NSLP eligibility rates for schools within project reach. Anti-displacement: document City policies (rent stabilization, affordable housing programs) even if citywide — it signals awareness.

TIP: Use CalEnviroScreen 4.0 (score ≥40.05) as your qualifier — most reliable and widely accepted
3

Consult the Corps — Right Now, Before the Application Opens

California Conservation Corps consultation is required every cycle for every application — your prior consultation doesn't carry over. Submit via the JotForm (for both CCC and Local Corps) as soon as the Cycle 8 window opens. Failure to consult = automatic −5 points. Intent not to use = −5 points. This is the single easiest deduction to avoid and one of the most common mistakes.

ACTION REQUIRED: Submit JotForm to CCC and Local Corps immediately when application opens
4

Large Infrastructure: Target Transformative, Not Just Incremental

CTC explicitly wants "transformative projects that significantly expand the active transportation opportunities in a community or region." For Large applications (5 pts), Transformative scoring considers: project as part of a larger walking/biking network, local fatality/injury reduction goals, prohousing policies, and support for existing/planned affordable housing. A corridor project connecting 3 neighborhoods to a major transit hub outscores a single-block sidewalk gap by design.

TIP: If your city is in HCD's Prohousing Designation Program, document it explicitly in the Transformative criterion
5

Get Listed in Your Active Transportation Plan Before Applying

Large project applications explicitly score higher under "Public Participation & Planning" if the project is listed in an adopted bicycle plan, pedestrian plan, SRTS plan, or ATP plan. Your CSAP (if it includes bike/ped elements) may qualify if adopted. For Cycle 8, any adoption before June 2026 works. ATP Plan projects (funded under the Plan application type) get 30 pts for DAC benefit and 25 pts for Implementation — most successful if applicant has NO existing eligible plan (first priority).

FOR CSAP: Adoption before June 2026 positions projects as plan-listed before Cycle 8 deadline
6

Use LSRP as Match — And Document It Precisely

No match is required for ATP, but leveraged funds boost score for Large and Medium applications (up to 5 pts). SB 1 LSRP apportionments are among the best match sources: no federal strings, received monthly, no competing application required. The signed commitment letter must be from your CEO or authorized officer. STIP funds are excluded from leveraging. In-kind, staff time, and non-infrastructure activities are not eligible for leveraging points.

TIP: Phase-by-phase funding plan through construction must be complete — partial funding plans receive zero leveraging points
7

Safe Routes to School Projects Are Strategically Valuable

SRTS projects are exempt from the $250K minimum funding request. They score under "Need" on student active transportation criteria and under "Safety" for school proximity. Projects must be within 2 miles of a public school, with school community as intended beneficiaries. SRTS designations significantly boost visibility in staff recommendations. In Cycle 7, 5 of 9 statewide-funded projects had SRTS components — showing the strategic value of school alignment even in large infrastructure applications.

TIP: Add an SRTS component to any infrastructure project within 2 miles of a school to gain scoring advantages
8

PSR Equivalency Must Be Airtight

Every application functions as a PSR equivalent — defining scope, cost, and schedule. The ATP application IS the PSR if it defines and justifies scope, provides a complete cost estimate for ALL phases (even pre-construction-only applications must show preliminary estimates for all phases), and the scope has independent utility. Caltrans staff specifically review PSR equivalency — applications that fail this review are flagged before scoring. Use the Caltrans PSR Equivalency Workshop materials as a checklist.

CRITICAL: Feasibility studies are NOT PSR equivalents. Cost estimates must cover all phases, not just ATP-funded phases.
9

MPO vs. Statewide — Know Your Competition Tier

If your project is in an MPO region (Bay Area, LA, SD, Sacramento, etc.), it competes in BOTH the statewide component AND is eligible for the MPO component if not funded statewide. Projects not selected statewide must be considered by the MPO — you can't opt out. Bay Area: MTC has ~$46M for Cycle 8 with regional guidelines that include equity priority community requirements. Scores in the 80s range can win MPO funding vs. 89–95 required statewide. MTC also allows matching fund waivers for low-income communities.

TIP: For Bay Area agencies — a strong application that just misses statewide funding still has a strong path through MTC's regional component
10

Past Performance Cleanup Before Cycle 8

CTC will assess and potentially deduct up to 10 points for poor past performance on any ATP project — including non-use of Corps as committed, adverse audits, or undelivered prior cycle phases. Run an audit of all your ATP project statuses now: Are user counts submitted? Are expenditure reports current? Any open corrective action plans with Caltrans? Resolve these before the application deadline. Non-compliance can also trigger placement on a Commission watch list requiring appearance.

CHECK NOW: Verify all prior ATP project reports and Corps use commitments are current at dot.ca.gov/programs/local-assistance
📊 Competitive Benchmarking — Strong vs. Typical ATP Application
Jun 22
Application Deadline
2026 · Via Submittable portal
Mar 19
Guidelines Adopted + Call Opens
March 19–20, 2026 · CTC
~$500M
Expected Available
$275M statewide · $46M MTC
None
Match Required
MPOs may require match; statewide does not
📅 Cycle 8 Key Timeline
💰 Fund Estimate — Component Distribution
50%
Statewide Component
~$250M · CTC competitive
40%
MPO Component
~$200M · by population
10%
Small Urban & Rural
~$50M · pops 5K–200K

🏘️ Bay Area (MTC) — Cycle 8 Regional Allocation

MTC expects ~$46M for the Bay Area MPO component in Cycle 8 (FFY27–30 programming years). MTC requires 11.47% match from project sponsors, waivable for low-income communities. Equity Priority Community projects get additional scoring consideration. Applications due to MTC as part of MPO process — check MTC for regional guidelines timeline (typically fall 2026).

📋 Fund Estimate Adoption — March 2026

The 2027 ATP Fund Estimate was adopted at the same CTC meeting as the Guidelines (March 19–20, 2026). The Fund Estimate sets the exact dollar amount per component. Review it immediately — it determines whether Small Urban & Rural is open to your jurisdiction and shows the exact federal/state funding split.

⚠️ New in Cycle 8 — Key Changes from Cycle 7 Guidelines

Quick-Build Pilot Program Returns — MPO Component Only

Quick-Build Projects return in the MPO Component via supplemental calls for projects. Must be submitted directly to the MPO — not the statewide competition. State-only funding designation required. Testing period of at least 6 months required. Semi-permanent materials that don't require excavation. Design-build preferred delivery method.

NEW: Quick-Build design costs may be included in the construction phase budget

Updated Disadvantaged Community Income Threshold

Cycle 8 uses updated ACS 2020-2024 data with a new statewide median. Median Household Income threshold: <$79,297.60 (80% of 2020-2024 statewide median, Census Tract ID 140 data). Verify your project area qualifies against the new threshold — some communities that qualified in prior cycles may not under updated data.

CHECK: Run your census tracts against updated ACS 2020-2024 data at data.census.gov

NSLP Threshold — 2024-2025 School Year Data

National School Lunch Program qualifier now uses 2024-2025 school year data (75%+ eligible students). Projects must be within 2 miles of qualifying schools. California Department of Education data is the required source. Update your DAC qualification analysis to use current-year school data — prior year data is not acceptable.

Cycle 8 Programming Years: FY27-28 through FY30-31

The 2027 ATP programs projects in four fiscal years: 2027-28, 2028-29, 2029-30, and 2030-31. Projects requesting PAED/PSE funding now must also include a construction application (with exceptions). Timeline this against your design completion, environmental clearance, and construction readiness for each programmed year.

TIP: Request construction funding in FY29-30 or FY30-31 if your project is early in design — more realistic than FY27-28

Baseline Agreement Threshold — $25M Total or $10M ATP

SB 1 Accountability requires Baseline Agreements for projects with total cost ≥$25M (all funds) or ATP funding ≥$10M — including large infrastructure projects programmed for pre-construction only. CTC will not approve allocations (except environmental phase and NI for combo projects) without an approved Baseline Agreement. Factor this into your project management timeline.

📋 Delivery Rules — What Triggers Fund Lapse
1

Allocation Deadline — June 30 of Programmed Year

Funds programmed to a project phase expire on June 30 of the programmed fiscal year. Allocation request must be on a Commission meeting agenda no later than the June CTC meeting of that year. CTC meets 6x/year — plan allocation requests 60 days in advance. Extension: up to 20 months additional (one time only).

2

Contract Award — Within 6 Months of Construction Allocation

Construction contracts must be awarded within 6 months of allocation approval. Do not award contract until CTC allocates — premature award makes costs ineligible. Extension: up to 12 months (one time). Alert: You should not even request construction allocation unless you are ready to advertise immediately.

RULE: Never award construction contract before CTC allocation — costs are permanently ineligible
3

Project Completion — 36 Months from Contract Award

After construction award, agency has 36 months to complete and accept the contract. Invoice Caltrans within 180 days after completion deadline. Extension: up to 12 months (one time). Final invoice triggers Local Agency Project Audit — retain all records 3 years post-final payment.

4

10-Year Rule — Pre-Construction to Construction

Projects must commence ROW acquisition or construction within 10 years of receiving pre-construction (PAED/PSE) funding. Must commence construction within 10 years of ROW funding. Violation requires repayment of ATP funds. Plan long projects carefully across funding cycles.

5

User Counts — Before, After, and 5-Year Post-Construction

Every project with programmed construction funds (including NI and combo projects) must submit: (1) pre-construction count, (2) at-construction-completion count, (3) 5-year post-construction count per the Count Methodology Guide. Failure = corrective action plan, Commission watch list, possible future ineligibility.

PLAN AHEAD: Build user count methodology into construction contract or consultant scope