Evidence reviewed through Jul 13, 2026
Automate preparation, not accountability.
The public record supports conditionally automated draft calculations for vehicle revenue miles and hours, assisted preparation with human method review for passenger boardings, and account-level reconciliation for operating expense. It does not support unattended filing. Urban reduced reporters certify direct NTD submissions; California rural Section 5311 subrecipients provide data through Caltrans OTGC, which supplies forms and files the statewide report.
- Conditional calculations
- 2
- Method reviews
- 1
- Reconciliations
- 1
- Unattended filings supported
- 0
What the public evidence supports
California law directs the State Controller’s uniform system to include data required by the U.S. Department of Transportation. That makes a shared source layer plausible. It does not erase the two reports’ scope, validation, audit, and certification rules. The State Controller requires a signed filing. Direct urban reduced NTD reporters complete annual CEO certification, while Caltrans supplies forms and files statewide on behalf of its rural Section 5311 subrecipients.
This slice compares published definitions only. It is not an official interpretation, compliance determination, system design, or finding about any agency’s current data readiness.
Do not collapse the two NTD reporting paths.
Urban reduced · direct NTD reporter
An urban agency operating 30 or fewer vehicles in maximum service generally files its reduced report directly. Its annual package includes CEO certification; urban reporters also follow the applicable independent-auditor statement controls. FFA-10 collects the four-field allocation by served area for directly reporting urban reporters.
California rural Section 5311 subrecipient
Caltrans reports to NTD on behalf of its subrecipients. OTGC supplies the intake forms and files the statewide summary, so the current OTGC workbook, validation rules, and intake calendar are required before building a rural production workflow.
California Department of Transportation · Federal Transit Administration
Field crosswalk
Where the definitions meet—and diverge.
| Measure | California TDA report | NTD reduced report | Assessment |
|---|---|---|---|
| Passenger boardings | Total Passengers — Annual Supplemental Operating Data Form | Unlinked Passenger Trips (UPT) RR-20; FFA-10 for direct urban reporting | Assistable · method review medium confidence |
| Vehicle revenue miles | Total Actual Vehicle Revenue Miles — Annual Supplemental Operating Data Form | Vehicle Revenue Miles (VRM) RR-20; FFA-10 for direct urban reporting | Conditionally automatable medium confidence |
| Vehicle revenue hours | Total Actual Vehicle Revenue Hours — Annual Supplemental Operating Data Form | Vehicle Revenue Hours (VRH) RR-20; FFA-10 for direct urban reporting | Conditionally automatable medium confidence |
| Operating expense | Total Operating Expenses Statement of Revenues, Expenses, and Changes in Fund Net Position | Operating Expense (OE) RR-20; FFA-10 for direct urban reporting | Reconciliation required high confidence |
Field findings
A prototype boundary for each value.
Field 1 of 4
Passenger boardings
Assistable · method reviewCalifornia TDA report
Total Passengers — Annual
All passengers boarded on unlinked passenger trips.
NTD reduced report
Unlinked Passenger Trips (UPT)
Boardings on public transportation vehicles during the fiscal year, counted each time a passenger boards, with mode-specific rules and approved counting or estimation methods.
Federal Transit Administration, Manual pp. 85–93 and 157–158
Finding
The core unit is aligned: both count unlinked boardings. Transfer still depends on matching report entity, fiscal year, mode, type of service, public-transportation scope, and the treatment of attendants, vanpool drivers, sponsored trips, and estimates.
Controls before reuse
- Map the reporting entity, fiscal year, mode, and type of service before aggregation.
- Retain the source method for each count, including APC, farebox, driver log, manual count, or approved estimate.
- Run exception checks for interlining, employees, attendants and companions, vanpool drivers, ferry occupants, and sponsored service.
- If counts are estimated, document the approved sampling method, precision, and any APC approval or benchmarking requirements.
- Require the responsible officials to review and certify the resulting submissions.
Evidence still needed
- Agency-level passenger-count source systems and data dictionaries
- Existing TDA and NTD aggregation workbooks or queries
- Sampling, APC, and manual-count procedures used by candidate agencies
Field 2 of 4
Vehicle revenue miles
Conditionally automatableCalifornia TDA report
Total Actual Vehicle Revenue Miles — Annual
Miles while in revenue service for the fiscal year by mode, excluding travel to and from storage facilities and other non-revenue travel.
NTD reduced report
Vehicle Revenue Miles (VRM)
Miles traveled while in revenue service, excluding deadhead, operator training, maintenance testing, and other non-revenue use; demand-response and taxi service have additional rules.
Finding
The published inclusions and exclusions are closely aligned. A shared calculation is plausible, but only after mode and type-of-service mapping and explicit handling of deadhead, demand-response, taxi, incidental service, and purchased transportation.
Controls before reuse
- Use actual trip- or block-level records and revenue-service flags; schedules or GTFS alone do not prove service operated.
- Separate mode and type of service before producing report totals.
- Document demand-response, taxi, incidental-service, and purchased-transportation rules.
- Reconcile annual totals to source operational records and investigate year-over-year exceptions.
Evidence still needed
- AVL, scheduling, dispatch, and contractor data availability
- Agency definitions for pull-out, pull-in, layover, deadhead, and no-show travel
- Current validation tolerances and exception-resolution workflows
Field 3 of 4
Vehicle revenue hours
Conditionally automatableCalifornia TDA report
Total Actual Vehicle Revenue Hours — Annual
Total actual hours of all vehicles in revenue service for weekdays, Saturdays, and Sundays, reported by mode.
NTD reduced report
Vehicle Revenue Hours (VRH)
Hours traveled while in revenue service; scheduled-service hours include running and layover or recovery time and exclude deadhead and other non-revenue use, with separate demand-response rules.
Finding
Both systems ask for actual revenue-service hours, but the California instructions are less detailed about layover and service-type boundaries. A common calculation should adopt explicit NTD-style event rules and retain a California-report aggregation view.
Controls before reuse
- Use actual timestamped operations data and define running, layover or recovery, deadhead, interruptions, and out-of-service time as separate event types.
- Apply the correct fixed-route, demand-response, and taxi rules before aggregation.
- Preserve weekday, Saturday, and Sunday subtotals required by the California form.
- Reconcile calculated totals to schedules, dispatch records, and contractor invoices where applicable.
Evidence still needed
- Availability and quality of actual versus scheduled time records
- Treatment of layover and recovery time in current California filings
- Purchased-transportation contract data and validation practices
Field 4 of 4
Operating expense
Reconciliation requiredCalifornia TDA report
Total Operating Expenses
Sum of the California form's operating-expense categories, which include depreciation and amortization line items.
California State Controller's Office, Instructions pp. 12–15
NTD reduced report
Operating Expense (OE)
Day-to-day operating costs reported on an accrual basis under the NTD Uniform System of Accounts; capital expenses and reconciling items such as depreciation, leasing, and interest are treated separately.
Finding
The California total is not a safe direct substitute for NTD operating expense. The forms share many FTA account concepts, but depreciation, amortization, leases, interest, capitalization thresholds, fully allocated costs, purchased transportation, and non-transit activities require an account-level reconciliation.
Controls before reuse
- Map each general-ledger account to the current California form and NTD USOA treatment.
- Produce a reconciliation schedule for depreciation, amortization, leases, interest, capital thresholds, and other reconciling items.
- Allocate shared and purchased-transportation costs consistently by mode and type of service.
- Tie the final values to audited financial statements when available and retain reviewer sign-off.
Evidence still needed
- Agency chart of accounts and existing TDA-to-NTD account mappings
- Audited financial statements and year-end adjustment schedules
- Cost-allocation plans, capitalization policies, and purchased-transportation contracts
Implementation guardrails
One source layer, two accountable reports.
- Use one canonical agency identifier and an explicit crosswalk to State Controller and NTD reporter identifiers.
- Record fiscal-year boundaries, mode, type of service, service-area allocation, source system, extraction time, transformation version, and reviewer for every derived value.
- Version the shared source layer across different report calendars; do not assume the NTD and State Controller filings use one immutable annual snapshot.
- Keep generated values in draft until report-specific validation passes and an authorized official approves submission.
- Retain the submitted value, source snapshot, transformations, exceptions, reviewer decisions, and later revisions as an audit trail.
- Treat changes to either reporting manual as versioned rule changes that require revalidation.
Next evidence step
Test the four-field mapping with two or three volunteer rural or small California operators using de-identified source extracts, their latest TDA and NTD workpapers, and the staff who prepare and certify each report.
Primary sources
Review the evidence directly.
- Transit Operator Financial Transactions Report Instructions for the Fiscal Year Ended June 30, 2025 California State Controller's OfficePublished Nov 18, 2025 · reviewed Jul 13, 2026
Current instructions linked by the State Controller for the 2024–25 Transit Operator Financial Transactions Report.
- California Public Utilities Code section 99243 California Legislative InformationPublished Jan 1, 2026 · reviewed Jul 13, 2026
Statutory annual-report requirement, audited-data language, and direction to include data required by the U.S. Department of Transportation.
- National Transit Database 2026 Policy Manual — Reduced Reporting Federal Transit AdministrationPublished Jun 30, 2026 · reviewed Jul 13, 2026
Current NTD policy manual for urban systems operating 30 or fewer vehicles in maximum service and for rural reporters, including State DOTs and subrecipients.
- Caltrans State Management Plan for Federal Transit Programs California Department of TransportationPublished Apr 21, 2026 · reviewed Jul 13, 2026
Current plan stating that Caltrans reports to NTD on behalf of its subrecipients, OTGC files the statewide summary, and OTGC supplies the reporting forms.