Justification for Increase to SSO Support Contract.docx
DOCX document 33 KB Posted
- Solicitation number
- 27-494DOT-FINAD-B-54032
- Issued by
- Illinois
About this file
This is a justification document for a contract increase to the State Safety Oversight (SSO) Support Contract between the Illinois Department of Transportation (IDOT) and a consultant providing rail transit safety expertise, planning support, training, administrative services, and oversight for the Chicago Transit Authority (CTA) rail transit system. The document outlines the Federal Transit Administration's (FTA) enforcement actions and special directives issued to IDOT due to persistent deficiencies in its SSO program, including Special Directive 22-31 (October 2022) requiring a risk-based inspection program, Special Directive 23-1 (October 2023) requiring increased staffing, and Special Directive 26-1 (March 2026) addressing critical systemic deficiencies. The contract's term extends through March 2028, with the current contract valued at $5,133,662.85 and $3,371,744.98 expended through February 2026.
The estimated additional funding requirement through March 2028 is $2,149,471.50, bringing the total contract not-to-exceed amount to $8,163,662.85. The cost breakdown includes $350,536.50 for inspections (3,250 hours for Rail Transit Safety Investigators/Inspectors and 200 hours for Principal Transit Safety Auditors), $802,632.00 for training material development and delivery (8,000 hours for Training Coordinators and 100 hours for Principal Auditors), and $996,303.00 for Safety Management Inspection (SMI) and special directive support (9,500 hours for Transit Safety Auditors and 400 hours for Principal Auditors). The consultant is expected to dedicate approximately 5-7 full-time equivalents to the program, with an anticipated ramp-up period of unknown duration. Funding is derived from Federal Transit Administration sources, with potential enforcement action consequences including withholding of SSO formula grant funds or up to five percent of the State's urbanized Area Formula Funding if compliance is not achieved.
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Other files
| File | Type | Posted |
|---|---|---|
| IL SSOA - Change Order Notice~2.pdf |
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Text version
Explanation of the FTA Special Directives The FTA may issue special directives to one or more named recipients of FTA funding when it:
· Believes that a recipient is engaging in conduct, or there is evidence of a pattern or practice of a recipient’s conduct, in violation of the Public Transportation Safety Program or any regulation or directive issued under those laws for which the Administrator exercises enforcement authority for safety;
· Determines that an unsafe condition or practice, or a combination of unsafe conditions and practices, exists such that there is a substantial risk of death or personal injury, or damage to property or equipment; or
· Determines that the public interest requires the avoidance or mitigation of a hazard or risk through immediate compliance.
FTA reserves the right to take additional enforcement action as necessary to ensure the safety of CTA’s rail transit system and the effectiveness of IDOT’s SSO program.
October 2022 - FTA issued 22-31 Special Directive to require the Illinois Department of Transportation to develop and implement a risk-based inspection program in accordance with changes to FTA’s Public Transportation Safety Program as required by the Bipartisan Infrastructure Law.
IDOT’s program for the CTA was submitted in October 2024 as required. It is the only program across the county not approved of by the FTA. The FTA continues to have concerns with IDOT’s technical capabilities to undertake inspections.
October 2023 – FTA issued Special Directive 23-1 to require the Illinois Department of Transportation (IDOT) to address a pattern of insufficient staffing in their State Safety Oversight (SSO) Program. IDOT must take action to increase staffing to align with the current needs of their SSO Program. Of four Findings, Finding 3 requiring IDOT to update the technical training program and Finding 4 requiring IDOT to ensure all staff have the required skills and competencies remain open.
April 2024 – FTA provided notice of proposed rulemaking regarding rail transit roadway worker protection. This new rule required IDOT to review the CTA’s new program for compliance and adopt by December 2, 2025, to continue monitoring the program for two years, as well as conduct an annual audit of the CTA for compliance.
March 2026 – FTA issued Special Directive 26-1 to require the Illinois Department of Transportation to take immediate action to address critical, persistent, and systemic deficiencies in its State Safety Oversight program for the Chicago Transit Authority rail transit system.
March 2026 – FTA initiated a Safety Management Inspection (SMI) of the Illinois Department of Transportation’s (IDOT) State Safety Oversight (SSO) program for the Chicago Transit Authority (CTA) rail transit system to identify the root causes of longstanding deficiencies in IDOT’s safety oversight.
The Requirements/Need for the Agency to Comply with Those Directives The FTA may take enforcement action for any violation of Special Directives or of the terms of any written plan adopted pursuant to the Special Directives, in accordance with FTA's authorities under 49 U.S.C. § 5329. Enforcement actions include, but are not limited to, requiring IDOT to conduct more frequent oversight of CTA, requiring IDOT to use Federal financial assistance to correct safety deficiencies, as well as financial penalties: (1) withholding SSO formula grant funds; (2) withholding up to five percent of the State's urbanized Area Formula Funding authorized under 49 U.S.C. § 5307; or (3) directing IDOT to use Federal financial assistance to comply with 49 U.S.C. § 5329(k).
Basis of Estimate - The Additional Funds will go to the Line Items Highlighted Below
| Original Not to Exceed |
| $1,140,775.20 |
| Original Contract Amount |
| $950,646.00 |
| +Amendment 1 |
| $150,000.00 |
| +Increase to max |
| $40,129.20 |
| +Amendment 2 |
| $1,258,646.20 |
| +Renewal 1 |
| $950,646.00 |
| +Increase Renewal |
| $832,949.45 |
| +Amendment 2 |
| $950,646.00 |
| Total Current Contract Amount |
| $5,133,662.85 |
| Total Contract Spent through February 2026 |
| $3,371,744.98 |
| Estimated Need through March 2028 |
| $2,637,068.43 |
| Total Contract Spent and Estimated |
| $6,008,813.41 |
| Estimated Shortfall Existing Work |
| ($875,150.56) |
| Estimated Cost to Support Inspections |
| $350,000.00 |
| Estimated Cost to Support Training/Materials |
| $800,000.00 |
| Estimated Cost to SMI and SD Support |
| $1,000,000.00 |
| Estimated Additional Work |
| $2,150,000.00 |
| Needed Increase |
| $3,025,150.56 |
| Total Not to Exceed |
| $8,163,662.85 |
Estimates Breakdown by Cost/Position for the Future Amendment Although not used to develop the estimate. That was the previous table. Those items have been broken down here for additional context.
| LABOR CATEGORY |
| ESTIMATED ADDITIONAL HOURS |
| FULLY LOADED HOURLY RATE |
| ESTIMATED TOTAL COST |
Estimated Cost to Support Inspections
$350,536.50
| Rail Transit Safety Investigator/Inspector |
| 3250 |
| $98.41 |
| $319,832.50 |
| Principal Transit Safety Auditor |
| 200 |
| $153.52 |
| $30,704.00 |
Estimated Cost to Support Training Materials
$802,632.00
Transit Safety Training Coordinator
| Develop Materials |
| 4000 |
| $98.41 |
| $393,640.00 |
| Provide Training |
| 4000 |
| $98.41 |
| $393,640.00 |
| Principal Transit Safety Auditor |
| 100 |
| $153.52 |
| $15,352.00 |
Estimated Cost to SMI and SD Support
$996,303.00
| Principal Transit Safety Auditor |
| 400 |
| $153.52 |
| $61,408.00 |
| Transit Safety Auditor |
| 9500 |
| $98.41 |
| $934,895.00 |
Other
| Administrative Staff |
| 0 |
| $49.21 |
| $0.00 |
ESTIMATED AMENDMENT NEEDED THROUGH MARCH 2028:
$2,149,471.50
This will require the consultant to dedicate approximately 5-7 FTEs to the program. We believe the consultant will need some time to ramp up but do not know how long that will take.
File details come from the government source that posted it. Updated .