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FTA Proposes Requiring 100% U.S.-Origin Components for Rolling Stock Overhauls

May.31.2012

To "reclarify" an issue the Federal Transit Administration (FTA) thought it had settled in its 2007 rulemaking, on May 21, 2012, the FTA provided notice (with opportunity to comment on or before June 20, 2012) of its interpretation that the statutory exception permitting acquisition of rolling stock with only 60% U.S.-origin components did NOT apply to overhauls, because overhauls are more akin to replacement and repairs. Engine rebuilds, on the other hand, which extend the useful life of the rolling stock, would continue to qualify for the reduced level of domestic content (but also subject, presumably, to the requirement that 60% of the subcomponents used in a rebuild must be U.S.-origin for the component to qualify as domestic).
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For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Alan W. H. Gourley
Partner – Washington, D.C., London
Phone: +1 202.624.2561 , +44.20.7413.1342
Email: agourley@crowell.com

Adelicia R. Cliffe
Counsel – Washington, D.C.
Phone: +1 202.624.2816
Email: acliffe@crowell.com