Certs Grants – Who’s Eligible?

The updated guidance from Treasury laid out the criteria for who is eligible for a CERTS grant. After the requirement of experiencing a revenue loss of 25% or more on an annual, calendar year basis from 2019 to 2020 as a result of COVID-19, the biggest criteria is that a company must be a “Qualifying Transportation Service Provider.” Treasury defines this as being one of the following four types of a provider:

1. Motorcoach transportation service provider
2. School bus transportation service provider
3. Passenger vessel transportation service provider
4. Pilotage vessel transportation service provider

Let’s walk through how Treasury defines these types of providers and how a company can demonstrate its eligibility.

Treasury defines a passenger vessel company means a private sector company whose principal business is carried out using one or more passenger vessels or small passenger vessels of the United States (as each is defined in 46 USC § 2101) that (a) are for hire with a capacity of 6 to 2,400 passengers and (b) have U.S. Coast Guard (USCG) issued Certificates of Inspection (COI).

Treasury then goes on to say that the company must demonstrate its eligibility as a qualifying transportation service provider. Let’s walk through how each type of provider may demonstrate its eligiblity:

Motorcoach Company:

1. Definition:
   • a private sector company, registered as an interstate carrier at the federal level or an intrastate carrier at the state level, whose principal business is providing passenger transportation services using one or more buses with an elevated passenger deck located over a baggage compartment (commonly known as an “over-the-road bus”) for local and intercity fixed-route service, commuter service, and/or charter or tour service.
2. How to demonstrate eligibility:
   • Have a current USDOT number or state registration number that Treasury can validate with the FMCSA or state departments/agencies
   • Listing the number commercial passenger vehicles and motorcoaches it operates so Treasury can validate the proportion of its businesses related to motorcoach transportation services

School Bus Company:

1. Definition:
   • a private sector company whose principal business is providing student transportation services under contract to a school, school district, or State department of education to carry students to and from school and/or to and from education-related events, activities, and competitions, using one or more school buses as defined in 49 CFR § 571.3. School buses must be designed for carrying more than 10 persons, and do not include buses designed or sold for operation as a common carrier in urban transportation.
2. How to demonstrate eligibility:
   • Have a current USDOT number or state registration number that Treasury can validate with the FMCSA or state departments/agencies
   • Copy of its primary or largest contract with a school, school district, or state department of education so Treasury can validate information.
   • Vehicle license plate numbers may as be submitted to help prove eligibility

Passenger Vessel Company:

1. Definition:
   • a private sector company whose principal business is carried out using one or more passenger vessels or small passenger vessels of the United States (as each is defined in 46 USC § 2101) that (a) are for hire with a capacity of 6 to 2,400 passengers and (b) have U.S. Coast Guard (USCG) issued Certificates of Inspection (COI).
2. How to demonstrate eligibility:
   • Provide the Vessel Name(s) and Official Number(s) as documented on the USGC issued COI
   • Copy of the COI to allow Treasury to validate the information

Pilotage Vessel Company

1. Definition:
   • a private sector company whose principal business is providing pilotage services regulated by a State in accordance with 46 U.S.C. § 8502, and does not mean an operator of vessels providing towing or other tug assist services.
2. How to demonstrate eligibility:
   • Provide a copy of its operating license issued by its state pilot commission and USGC Certificate of Inspection

We’ll walk through the application process, getting prepared for the portal to open, and what you can do to plan in the next few posts.