Can an application for funding originally submitted via RAISE be repackaged and submitted via the Reconnecting Communities Pilot Program?

The Rebuilding American Infrastructure with Sustainability and Equity (“RAISE”) Grant Program (specifically, the Local and Regional Project Assistance Program) is a competitive grant program significantly expanded in the Infrastructure Investment and Jobs Act (“IIJA”).[1] The 2022 RAISE Notice of Funding Opportunity (“NOFO”) closed on April 14, 2022.[2] The Reconnecting Communities Pilot Program, also established under the IIJA, is a competitive grant program that will open for applications in Summer 2022.[3]

A review of the IIJA text, the program descriptions as listed in the Bipartisan Infrastructure Law Guidebook, the RAISE NOFO and amendment, and other program-specific guidance that has been published by the U.S. Department of Transportation does not explicitly indicate any prohibition on submitting applications for funding to both programs for a project that is substantially similar in nature.

However, while both programs offer various types of funding opportunities, including planning and construction grants, prospective grant applicants should note crucial differences in eligible uses, federal cost sharing restrictions, and other eligibility requirements. For example, RAISE permits various state, regional, and local governments to apply for both planning and construction projects,[4] while the Reconnecting Communities Pilot Program requires the applicant for construction projects to be the owner of the transportation facility in question, usually the state or local government agency with jurisdiction over transportation.[5]

For additional information on the similarities and differences in characteristics between the respective programs, refer to the IIJA Guidebook,[6] or original IIJA text.

Last Updated: July 10, 2022

[1] The White House, A Guidebook to the Bipartisan Infrastructure Law for State, Local, Tribal, and Territorial Governments and Other Partners, (as of January 31, 2022), at 18, available at: https://www.whitehouse.gov/wp-content/uploads/2022/01/BUILDING-A-BETTER-AMERICA_FINAL.pdf.

[2] Department of Transportation, “RAISE Discretionary Grants Program,” available at: https://www.transportation.gov/RAISEgrants.

[3] Department of Transportation, “Reconnecting Communities Pilot Program,” available at: https://www.transportation.gov/grants/reconnecting-communities.

[4] Department of Transportation, “RAISE Discretionary Grants,” available at: https://www.transportation.gov/RAISEgrants.

[5] Department of Transportation, “Reconnecting Communities Pilot Program,” available at: https://www.transportation.gov/grants/reconnecting-communities.

[6] The White House, A Guidebook to the Bipartisan Infrastructure Law for State, Local, Tribal, and Territorial Governments, and Other Partners, (as of January 31, 2022), at 18 and 34, available at: https://www.whitehouse.gov/wp-content/uploads/2022/01/BUILDING-A-BETTER-AMERICA_FINAL.pdf.