Public Comment Open Through June 13 on Proposed Updates to RTA’s Performance-Based Capital Allocation Process

As part of our commitment to transparent capital planning, the RTA is seeking public input on proposed updates to the performance-based capital allocation process for CTA, Metra, and Pace. The comment period is open through Friday, June 13, 2025, and feedback can be submitted to communications@rtachicago.org.

The proposals under consideration mark a major milestone in the implementation of the region’s performance-based programming framework, which is used to allocate federal formula and state PAYGO capital funds across the Chicago Transit Authority (CTA), Metra, and Pace. The proposed updates would formalize withholding and redistribution policies tied to project delivery performance, ensuring continued alignment between capital investment and regional goals.

A Brief History of Performance-Based Allocation

In 2019, the RTA Board of Directors asked for recommendations to change the long-held practice of distributing capital funds based on fixed percentages. In response, RTA developed a performance-based allocation methodology grounded in three principles: addressing capital reinvestment needs, incentivizing project delivery, and advancing regional policy priorities such as equity and accessibility.

The new framework was approved by the RTA Board in 2021 following collaboration with the Service Boards and a public comment period. It has since guided programming decisions across multiple capital cycles and formed the basis for allocating over $1 billion in federal and state capital funds in 2025 alone. However, implementation to date has not included actual withholdings or redistribution of funds based on performance metrics. The proposed changes would complete that implementation.

Why It Matters

The RTA oversees a 2025-2029 Regional Capital Program of nearly $9.5 billion that funds significant, necessary improvements to the transit system’s built assets such as replacing out of date buses and trains, updating unsafe bridges, transitioning the region to zero emission vehicles, expanding the transit network through projects like the Red Line Extension, and more.

The region’s transit system faces significant capital challenges. According to the 2025 Capital Asset Condition Report, 25 percent of the system’s assets exceed their useful life, representing a backlog of nearly $30 billion. While this reflects improvement from 31 percent in 2016—thanks in part to new investment from the Infrastructure Investment and Jobs Act and Rebuild Illinois—sustained annual funding of approximately $4 billion is needed to bring all assets into a state of good repair within 20 years.

These changes are a critical step toward a more enforceable, outcomes-driven capital funding model—one that ties investment to performance and accountability across all transit agencies.

At the same time, there is growing recognition that transit governance and funding structures must evolve. As part of Transforming Transit and RTA’s legislative proposal that would implement the rider-focused outcomes within that vision, the agency has recommended reforms to unify capital planning, increase transparency, and strengthen the region’s ability to advocate for and manage investment. A more robust, enforceable performance-based capital allocation process aligns with these goals by:

Reinforcing the need for timely and efficient project delivery
Rewarding investments that advance shared regional priorities
Promoting coordination between transit agencies
Ensuring that limited funds are targeted where they are most needed and most likely to succeed

These updates reflect the kind of unified, transparent capital planning envisioned in the RTA’s legislative proposal for a stronger, more accountable regional transit system.

Summary of Proposed Changes

The RTA is proposing several updates to the allocation process that would take effect beginning with the 2026-2030 Capital Program:

1. Implementation of Withholding Mechanism

The original 2021 policy outlined performance metrics but did not establish a mechanism for enforcing them through the withholding of funds. The proposed changes would withhold up to 20 percent of annual federal formula and state PAYGO funds from Service Boards that do not meet performance goals based on three-year averages. These goals are:

Average Age of Funds: remain under 2.5 years
Percent of Funds Spent: At least 20% of available funds be spent annually

Service Boards that fall short of these benchmarks would see a portion of their capital allocations withheld for potential redistribution.

2. Adjustments and Exceptions to Performance Metrics

Recognizing the complexity of capital project delivery, RTA staff are proposing two key exceptions:

State Match Exemption: Up to 25% of State PAYGO funds programmed as match for federal discretionary grants would be exempt from performance calculations. This encourages strategic leveraging of state funds to attract competitive federal dollars, even if such projects take longer to deliver.
Project Start Date Adjustments: When delays exceed 90 days and are due to factors outside agency control—such as permitting and environmental reviews, vendor-related delays (documented in change orders), land acquisition, or third-party concurrence—the project start date may be adjusted. This prevents penalizing Service Boards for issues that are not reflective of internal performance.

To qualify, agencies must document these delays annually, including the amount of remaining funds, cause of delay, and expected timeline. RTA staff will review and verify these claims as part of the withholding calculation process.

3. Framework for Redistribution of Withheld Funds

Funds withheld under this policy would be pooled and redistributed through a competitive process once the total exceeds $10 million. Each Service Board would be eligible to submit 1–3 projects for consideration. Final funding decisions would be based on a scoring system developed by RTA staff and guided by Board-approved priorities.

Examples of potential priorities include:

RTA-led regional projects or interagency coordination efforts
Match for regional competitive grant opportunities
Projects that advance equity, climate resilience, or other regional goals

A selection committee would score applications, and funding would be awarded to top-ranked projects. This process introduces a new mechanism to reward high-performing, high-impact initiatives while maintaining transparency and accountability.

Opportunities for Public Engagement

The proposed updates to the allocation framework are now open for public review and comment. Stakeholder input will inform the final proposal, which will be presented to the RTA Board for a vote in August 2025. If approved, the changes will be incorporated into the marks for the 2026-2030 Capital Program, impacting how federal and state capital funds are distributed across the region’s transit system starting in 2030.

RTA encourages all interested parties—including riders, community organizations, partner agencies, and local governments—to review the proposal and comment.

Comments must be submitted by Friday, June 13, 2025, via email to: communications@rtachicago.org.