As part of GIIA’s ongoing advocacy on behalf of members , we have submitted a formal response to the U.S. Department of Transportation’s (USDOT) Request for Information (RFI) titled Advancing a Surface Transportation Proposal That Focuses on America’s Most Fundamental Infrastructure Needs.
USDOT’s RFI is a critical step in the process of developing the next surface transportation reauthorization bill. In our response, we have emphasized d a core message that has shaped our policy engagement across the U.S. market ever since our inception nearly 10 years ago: private capital must be a central part of the solution to modernizing and expanding the nation’s infrastructure. *
While the Infrastructure Investment and Jobs Act (IIJA) represented a significant investment in public infrastructure, federal funding alone is simply insufficient to close the estimated 3.7 trillion-dollar infrastructure gap over the next decade. The Trump administration has a unique opportunity to move the dial. A stronger, more deliberate partnership with private capital can deliver on the scale, efficiency, and resilience required for 21st century American infrastructure.
Key points of our submission
Permitting reform
Permitting remains one of the most obstinate barriers to infrastructure delivery. We e outline our support for full implementation and strengthening of the FAST-41 provisions, including the introduction of stricter timelines, enhanced interagency coordination, and public tracking of permitting milestones.
Notably FAST-41 lacks mechanisms to penalize agency delays or resolve interagency disputes in a timely manner. Consequently, a binding resolution timeline is needed, and fiscal penalties need to be considered to encourage compliance and reduce permitting bottlenecks.
We also recommend amending the National Environmental Policy Act (NEPA) to introduce FAST-41 style coordination, escalation and accountability to other infrastructure legislation. Delays in environmental reviews and fragmented agency coordination can hinder large-scale infrastructure projects. These challenges undermine investor confidence.
Streamlining these processes and harmonizing them against state-level permitting and planning is critical to accelerating economic growth, enhancing energy resilience, and closing the U.S. infrastructure funding gap.
Public-private partnerships
Federal support for public-private partnerships (P3s) remains essential to unlocking broader use of this delivery model at the state and local level. GIIA encourages federal investment in capacity building through grants that support the creation of state-level P3 offices and the development of P3 enabling legislation.
We also see an expanded role for the Build America Bureau in providing technical assistance, model procurement frameworks, and advisory services to public agencies. GIIA continues to support the expansion of Build America Bureau-administered grant programs, such as Innovative Finance and Asset Concession Grants and the Regional Infrastructure Accelerators Program. In addition, we urge the federal government to consider a U.S. asset recycling initiative, modelled on international examples such as Australia’s program, which has successfully mobilized private capital by monetizing underutilized public assets.
Federal credit and investment programs
Modernizing federal credit programs such as Transportation Infrastructure Finance and Innovation Act (TIFIA), Water Infrastructure Finance and Innovation Act (WIFIA), and Railroad Rehabilitation and Improvement Financing (RRIF), is critical to reducing project risk and encouraging private investment.
GIIA supports the streamlining of application processes, the development of a unified credit portal across agencies, and the introduction of a shared underwriting framework to improve coordination and predictability. These improvements, coupled with pre-development credit support to assist with earlystage permitting and environmental review, would significantly improve the attractiveness and accessibility of these programs for infrastructure investors and developers.
Tax incentives
Targeted tax incentives remain a powerful tool to attract long term institutional capital. GIIA recommends greater clarity on eligibility for infrastructure-related tax credits, particularly as new federal energy and clean transportation incentives are implemented. We support expanding the use of Private Activity Bonds (PABs) by raising or removing the existing volume cap, because once a cap is reached, public authorities are discouraged from pursuing P3s even when they offer a better deal. If the cap were removed altogether, it would eliminate artificial constraints on projects that deliver a clear public benefit.
Additionally, we support the consideration of tax credit bonds or refundable tax credits; this is because the existing framework only benefits investors with a sufficient taxable income. Introducing these structures broadens the investor base to pension funds and foreign investors from allied countries, as well as increasing liquidity for infrastructure transactions, to support U.S. infrastructure growth.
Budgetary reforms
Outdated federal budget scoring rules continue to limit the full potential of private sector participation in infrastructure delivery. Currently, existing budget policies treat long-term infrastructure partnerships as if they were capital leases requiring full upfront funding regardless of risk transfer, project structure, or life-cycle value.
These outdated rules create a bias against private investment in federal infrastructure. GIIA urges policymakers to revise current Office of Management and Budget scoring rules to distinguish long term infrastructure concessions from leases and to revisit models such as the Military Housing Privatization Initiative, which allowed many P3 projects to be treated as non-budgetary. These reforms would allow greater flexibility for infrastructure transactions and better reflect the long-term economic value of private investment.
Workforce development
In GIIA’s submission, we underline that beyond financing projects, infrastructure investment must also address the workforce challenges that limit the speed, efficiency and scale of project delivery. To this end, we support the expansion of federal grants focused on technical assistance and workforce training, particularly in underserved communities and regions with limited access to infrastructure expertise. Supporting the next generation of engineers, project managers, and skilled tradespeople is essential to sustaining a robust and equitable infrastructure pipeline, as well as providing well-paid jobs for hardworking Americans.
Our advocacy and engagement plans
GIIA’s response to the USDOT’s Request for Information is part of our broader engagement strategy. Members can stay informed and involved as weapproach the surface transportation reauthorization deadline on September 30, 2026.
This fall, GIIA will meet directly with key members of Congress, relevant committees, and Administration officials, including a continuing dialogue with the Build America Bureau, to reinforce our recommendations and ensure that the next surface transportation bill reflects the vital role of private capital.
We will continue to emphasize that future legislation must not only fund U.S. infrastructure but transform how it is delivered. GIIA remains committed to working with federal and state-level policymakers to improve the conditions under which investors can contribute to meeting the nation’s infrastructure needs.
To access GIIA’s full submission to USDOT on August 20, 2025, please click here.
*GIIA’s submission to USDOT draws directly from our white paper, Building a New Foundation for U.S. Infrastructure, published earlier this year at our Infrastructure Week Symposium. The paper outlines a comprehensive and pragmatic policy framework to unlock private investment in U.S. infrastructure.