$140.2 Billion and Counting: Why Your EAM System Is Now Your Most Important SGR Compliance Tool
By: Bill Carrick
The Number Every Transit Asset Manager Needs to Explain
The FTA’s State of Good Repair National Backlog Analysis, released in January 2025, put the nation’s transit infrastructure repair deficit at $140.2 billion. That figure represents a $38.8 billion increase from the 2018 baseline — with inflation alone accounting for nearly half the growth. The remainder has arrived through expansion of new track miles, aging tunnels, deteriorating bridges, and decades of deferred capital investment that compounded faster than formula grants could address.
For the policy community, this is a funding story. For the transit asset manager sitting across from a CFO, a capital program review board, or an FTA auditor, it is a data problem.
Every dollar of that $140.2 billion must eventually be inventoried, condition-assessed, prioritized, and reported — to your board, your state oversight body, and increasingly to the FTA through mandatory annual submissions. The system that generates, holds, and exports that data is your Enterprise Asset Management platform. And as of 2025-2026, the FTA has made that connection explicit in federal regulation.
What Changed: NTD’s 2025-2026 Asset Reporting Overhaul
In July 2025, the FTA published a Federal Register notice updating National Transit Database (NTD) reporting requirements for report years 2025 and 2026. The changes were substantive — and they went largely unnoticed outside the compliance and asset management community.
Three changes stand out for transit operations directors and asset managers.
First, FTA eliminated the Stations and Maintenance Facilities form (A-10) and replaced it with a single, unified Transit Asset Management Facilities form (A-15). This consolidated form captures ADA accessibility status, asset condition ratings, and capital planning timelines for all passenger stations and maintenance facilities under a single annual submission. What was previously two reporting streams is now one — and the data requirements are more granular.
Second, FTA added three new asset categories to improve SGR estimation and modeling accuracy. These new categories are designed to align NTD submissions more precisely with the Transit Economic Requirements Model (TERM), which is FTA’s national infrastructure modeling tool and the basis for congressional reporting on system condition.
Third, the TAM Final Rule’s annual reporting obligations — an asset inventory, condition assessments, performance targets, and a narrative report — are now fully integrated into the NTD submission process. These are not planning documents. They are regulatory compliance submissions with consequences for formula funding eligibility.
The March 2026 Federal Register notice for the SGR Program information collection review signals that FTA is actively tightening the documentation chain between what agencies report and what they receive in formula grants.
The EAM System Is the Source of Record FTA Is Now Asking For
When an NTD Asset Form asks for the condition rating of your fleet, the remaining useful life of your maintenance facilities, or the performance target trajectory for your fixed-guideway infrastructure, the only authoritative source for those numbers is your Enterprise Asset Management system.
If your EAM platform is not generating structured condition assessment data — linked to asset IDs, categorized by FTA TERM asset class, and updated on a documented inspection cycle — your compliance team is building NTD submissions from spreadsheets, manual records, and estimated age-proxy condition scores. That creates audit exposure.
If the FTA conducts a Triennial Review and the data in your NTD submission does not reconcile with your TAMP or your EAM asset records, the findings range from corrective action plans to competitive grant disqualification. For agencies competing for the $4.75 billion Rail Vehicle Replacement Program — a competitive grant, not a formula allocation — data defensibility is a selection factor.
The TAM-EAM-NTD Pipeline That FTA Requires You to Build
The compliance architecture FTA has constructed flows in one direction: from physical assets, through your EAM, into your TAMP, and out through NTD submissions to the federal reporting framework.
Your physical assets are tracked in your EAM — work orders, preventive maintenance schedules, inspection history, condition grades, and remaining useful life calculations. That data feeds your Transit Asset Management Plan, which sets performance targets and prioritizes investment. Your TAMP is then the source document for your NTD TAM submissions, which inform FTA’s TERM model and — ultimately — the formula funding distribution your agency receives.
The problem most transit agencies face is that this pipeline has gaps. EAM systems hold condition data in formats that do not map cleanly to TERM’s asset classification schema. Inspection records are incomplete or entered as free text rather than structured fields. Asset hierarchies do not align between the EAM and the TAMP. PM work orders close without capturing condition outcomes.
Agencies that close these gaps — by configuring EAM asset classes to mirror TERM taxonomy, automating condition score exports, and linking PM records to NTD submission workflows — gain two durable advantages: cleaner annual compliance and a faster, more defensible grant application process.
Three Agencies Showing What Progress Looks Like
The Maryland Department of Transportation’s Maryland Transit Administration (MDOT MTA) has provided one of the most transparent documented examples of active SGR backlog reduction. Between 2023 and 2025, MDOT MTA reduced the percentage of its assets rated below the SGR threshold from 16.2% to 14.4%, with a funded trajectory targeting 5.4% by 2027 and 1.3% by 2031.
The Metropolitan Transportation Authority of New York City (MTA NY) submitted a $68.4 billion 2025-2029 Capital Plan — nearly 95% of which is categorized as rebuilding and improving existing assets. Within that plan, the MTA identified $11.5 billion in specific SGR, modernization, and accessibility projects currently without identified funding. Presenting that level of project-level granularity requires an EAM platform capable of tracking asset condition and remaining useful life at the sub-system level.
Transport for London (TfL) deployed IBM Maximo Application Suite to unify maintenance operations across its entire network onto a common platform. The deployment gave field teams real-time access to work orders and asset histories, and the resulting condition data integrity has supported TfL’s ability to build investment cases with the asset-level specificity that regulators and funders increasingly require.
The Condition Data Quality Problem Nobody Wants to Own
The weak link in most transit agencies’ SGR compliance chain is not funding or policy. It is condition data quality inside the EAM.
FTA’s TERM model assigns every asset a condition score between 1 (poor) and 5 (excellent), based on either observed inspection data or age-based estimation when inspection records are absent. If your EAM inspection records are incomplete, inconsistent, or tied to asset IDs that do not match your NTD asset inventory, your TERM condition scores will be calculated by age proxy.
Age-proxy scoring is systematically inaccurate. It assumes that all assets of the same class deteriorate at the same rate regardless of maintenance quality, operating environment, or material type. For a well-maintained bus fleet that runs above industry average MDBF (mean distance between failures), age-proxy scoring will overstate deterioration. For a rail signal system that has been repeatedly deferred, it will understate it.
The most common root causes are inspection workflows that close without a structured condition outcome, condition assessments logged as free text rather than scored fields, and PM records that capture work performed but not the condition state observed. Closing these gaps is a data governance exercise, not a capital project.
What EAM Features Directly Support SGR Compliance
Not all EAM platforms are built equally for transit’s regulatory environment. The features that matter most for SGR compliance reporting are specific.
Structured condition assessment modules that capture FTA TERM-compatible ratings (1–5) at the asset and sub-asset level — not binary pass/fail inspection fields — are the foundation. Asset lifecycle tracking with remaining useful life calculations that align with FTA’s useful life benchmarks by asset class is the second requirement. Configurable export templates that map EAM asset records to A-20, A-15, and TAM submission fields without manual re-entry eliminate the reconciliation bottleneck most compliance teams face annually. Integration between the EAM and a capital planning or Asset Investment Planning (AIP) module ensures SGR-prioritized investments flow directly from condition data into the TAMP project pipeline.
IBM Maximo Application Suite, Hexagon (Infor EAM / HxGN EAM), and IFS EAM are the platforms most commonly deployed in large, complex transit environments. All three support condition scoring and asset lifecycle modeling, but transit-specific configuration quality varies significantly by implementation partner.
The Funding Multiplier: Strong Asset Data Wins Grants
In FY2026, FTA’s total SGR program funding reaches approximately $4.8 billion — the highest annual allocation in IIJA’s five-year history — with the formula portion distributed to eligible fixed-guideway and high-intensity motorbus operators. Nationally, that funding serves a backlog that is currently 36 times the annual grant amount.
For individual agencies, the competitive Rail Vehicle Replacement Program — funded at $300 million annually under IIJA — is decided in part by the quality and defensibility of asset condition data supporting each application. An agency that demonstrates a documented EAM-to-TAMP-to-NTD data chain, with condition assessments updated within the last 24 months and NTD submissions that reconcile to physical asset inventories, is presenting a materially stronger case than one relying on age-proxy estimates.
The ROI calculation for EAM data governance belongs in the capital program conversation — not the IT budget.
What to Do Before Your Next NTD Submission
For transit asset managers preparing for the 2025-2026 NTD reporting cycle, the highest-priority actions are:
Start with an asset inventory reconciliation: audit your EAM asset records against your current NTD asset inventory. Identify every asset ID mismatch, missing condition rating, and TERM classification gap.
Map your EAM asset classification schema to FTA’s TERM taxonomy. If your facility assets are not categorized to the FTA class and sub-class level, your SGR condition reporting requires manual translation every submission cycle.
Review your inspection workflows for condition score capture. Every PM work order that closes without a structured condition outcome is a missed field observation that your TERM model will replace with an age estimate.
If you are preparing for a TAMP update or a capital plan cycle in 2026 or 2027, the data governance groundwork needs to begin now.
The Bottom Line
The $140.2 billion SGR backlog is a policy number. But behind every dollar of it is an asset record, a condition rating, an inspection history, and a remaining useful life estimate. Those records live — or should live — in your EAM system.
FTA has structured its entire compliance framework around the assumption that transit agencies maintain reliable, structured, field-verified asset data. The 2025-2026 NTD updates formalize that assumption as a reporting requirement. The March 2026 SGR information collection review signals that the documentation chain is being examined more closely.
The transit asset managers who will compete most effectively for the $3.85 billion flowing through FTA’s SGR program this year are the ones whose EAM systems speak the same data language as FTA’s compliance framework.
That language is condition data. The question is whether your platform is fluent in it.
Sources
- ARC Advisory Group, “MRO Inventory Optimization in Industrial Operations,” 2025.
- Deloitte, “Manufacturing Supply Chain Resilience Benchmark Report,” 2025.
- LNS Research, “Industrial Inventory Transformation: Benchmarks and Best Practices,” 2025.
- IBM, “Maximo Application Suite 9.1 Product Overview,” March 2026.
- Verdantix, “EAM Market Analysis and Vendor Landscape,” January 2026.
- MarketsandMarkets, “Enterprise Asset Management Market — Global Forecast to 2030,” December 2025.
