Posts in Policy.

The Federal Railroad Administration (FRA) has released its latest Positive Train Control (PTC) implementation progress report for the 2nd quarter of 2018. The FRA’s latest report indicates that railroads are making steady progress toward PTC compliance.

FRA says that 15 railroads have installed 100% and 12 railroads have installed between 95 and 99% of the mandated PTC system hardware. In addition, all but one railroad has acquired sufficient spectrum required for PTC Implementation.

FRA states that railroad implementation of PTC has improved since December 2016, where ...

In an effort to promote project flexibility, funding innovation, efficiencies and timely implementation, this week the Federal Transit Administration (FTA) released its final rule regarding P3s (and other private involvement) in public transportation projects.

The primary goal of FTA’s Private Investment Project Procedures (or PIPP), new 49 C.F.R. Part 650, is to identify and address FTA requirements that are impediments to the greater use of public-private partnerships and private investment in public transportation capital projects, while protecting the public ...

Posted in Legislation, Policy

President Trump recently signed into law a repeal of the MPO Coordination and Planning Area Reform rule less than a year after the rule was finalized by the Obama administration’s Federal Highway Administration and Federal Transit Administration. The rule, which was largely unpopular with local metropolitan planning organizations (MPOs) across the country, aimed to consolidate many MPOs. As a demonstration of just how unpopular the rule was, the bipartisan repeal effort unanimously passed in the Senate and overwhelmingly passed in the House.

The MPO Consolidation Rule was ...

Posted in Financing, News, P3s, Policy

On Tuesday, May 16, 2017 the Senate’s Committee on Environment and Public Works Subcommittee on Transportation and Infrastructure will hold a hearing titled Leveraging Federal Funding; Innovative Solutions for Infrastructure.

The stated purpose of the hearing is for Senators to examine the need for more public sector funding and private sector financing in the Federal Highway Program.  To this end, the Subcommittee has scheduled the following individuals to testify on this topic:

  • Eric Garcetti (Mayor, City of Los Angeles; Chair of U.S. Conference of Mayors Infrastructure ...
Posted in Legislation, News, Policy

It’s been a productive time for advocates of water in the U.S. with President Obama signing into law the Water Infrastructure Improvements for the Nation Act (WIIN).  WIIN includes the Water Resources Development Act of 2016 (WRDA), together with provisions to authorize critical water projects  and improve drinking water infrastructure, water storage and supply, flood control and waterways across the nation.

A summary of some of WIIN’s key attributes are set out below:

  • WIIN authorizes Congress to provide $20 million for the Water Infrastructure Finance and Innovation Act ...
Posted in Legislation, Policy

U.S. Transportation Secretary Anthony Foxx, senior Department staff, and even an official from the White House gathered at U.S. Department of Transportation headquarters on July 20th to celebrate the grand opening of the Build America Bureau. After sharing a cake emblazoned with its logo, the dignitaries led a tour through the Bureau’s new office space in what used to be the library, replete with glass offices, motorized desks, and curved computer monitors. Compared to the cubical-farm offices of the modal administrations, the Bureau is clearly something different and new, and ...

Posted in Policy

Lower gas prices and decreased revenue from California’s Price Based Excise Tax (PBET) on gasoline are taking their toll on the state’s transportation funding.  California Transportation Commission (CTC) staff recently recommended enormous decreases in the upcoming five-year State Transportation Improvement Program (STIP).  The CTC Commission will consider the staff’s recommendations and is expected to make a final decision at its meeting on May 18 and 19.

The staff’s recommendations include no new transportation projects in the next five years, as well as ...

For years, policymakers and economists around the country have been well aware that the federal gas tax is dying.

In its report to Congress, the National Surface Transportation Infrastructure Financing Commission, on which I was honored to serve, made clear that we must replace the 18.4 cent federal gas tax with other means of funding transportation in order to maintain and improve our highways, bridges and transit systems in the United States.

The commission recommended a road user charge as the most effective approach to solving this problem.

[If] we fail to address the immediate ...

On March 31, 2015, Congressman John K. Delaney (D-MD) spoke at the Washington Briefing of the International Bridge, Tunnel and Turnpike Association (IBBTA) in Washington, DC.  At the event, Congressman Delaney provided an update on a bipartisan bill he has sponsored known as The Infrastructure 2.0 Act to fund the federal highway program.  The bill uses international corporate tax reform to provide a six-year funding source for the Highway Trust Fund.  Specifically, the bill establishes a mandatory, one-time 8.75% tax on existing overseas profits accumulated by U.S. multi-national ...

Posted in News, Policy

Federal transportation officials are contemplating new contract rules that would make it easier for states and cities to hire local residents to work on transportation projects.  Federal rules currently prohibit the Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA) from allowing contract provisions that do not directly relate to the bidder's performance of work.  Thus, local hiring provisions have not been allowed in procurements for federally funded projects.  This month, however, U.S. Transportation Secretary, Anthony Foxx, announced a ...

Twitter Facebook LinkedIn
Tags: FHWA, FTA
Posted in News, Policy

The Second Annual Conference of the Mileage-Based User Fee Alliance (MBUFA) was held in Washington, DC on February 24, 2015.  The MBUFA is a non-profit organization that promotes awareness and education about mileage-based user fees as an alternative for the future funding of improvements to the U.S. transportation system.  Attendees included policy makers, public sector representatives and private sector stakeholders weighing in on the topic Sustainable Transportation Funding, Road User Fees: Is There Another Option for Achieving Financial Sustainability?   The concept of a ...

Posted in News, Policy

This Friday, January 23, 2015, California will take the first step in investigating a road user charge pilot program as an alternative to the gas tax when the CTC convenes the Road User Charge Advisory Committee meeting.  The committee was created last year by SB 1077 which authorizes a pilot study.  California joins a handful of other states that are exploring road user charge pilot programs, including Oregon, Washington, and Minnesota.

The 15 member committee is made up of representatives of local and regional agencies, privacy advocates, auto groups and state officials.  According ...

Posted in News, Policy

The American Association of State Highway and Transportation Officials (AASHTO) recently released an updated version of its popular roadmap of US transportation funding options, Matrix of Illustrative Surface Transportation Revenue Options, which may be accessed here.

The tool examines the five surface transportation revenue sources currently in place and considers 33 other potential sources of revenue. Updates to the tool include a bubble display and bar chart that allow users to see how much revenue the funding sources considered might generate. The tool is intended to ...

Twitter Facebook LinkedIn
Tags: AASHTO
Posted in P3s, Policy

On September 17, the House Transportation & Infrastructure Committee’s Panel on Public-Private Partnerships (P3s) released its report and recommendations.  The group, empaneled in February of this year, was tasked with examining issues regarding public-private partnerships across all aspects of the Committee’s jurisdiction.  The panel held two hearings and seven roundtable discussions in addition to other meetings and briefings. The report recognizes that the nation’s infrastructure needs are extraordinary and P3s in certain situations can provide innovative ...

Posted in Policy

Earlier this week, on August 25, 2014, the Federal Transit Administration (FTA) published Circular 7050.1, providing much anticipated guidance for grantees interested in pursuing joint development projects within FTA’s legal and regulatory framework.  The circular incorporates joint-development related provisions from MAP-21, and is intended to clarify FTA’s policy and serve as its single guidance document on the subject.

Specifically, the circular: (1) defines the term joint development; (2) explains how a joint development project can qualify for FTA assistance; ...

Posted in Policy

Secretary of Transportation Anthony Foxx chaired a virtual town hall meeting, entitled Moving from Uncertainty to Long-Term Transportation Investment, on August 6, 2014.  The town hall was open to the general public, as well as business leaders, transportation advocates, and state and local government officials.  Secretary Foxx discussed the United States Department of Transportation’s (US DOT) vision for the future of transportation, as well as answered questions from attendees about transportation policy.

In his opening remarks, and throughout the question and answer ...

Posted in Policy

Congress passed a bill (HR 5021) to provide a short-term funding patch for the Highway Trust Fund (HTF), just one day before the United States Department of Transportation was scheduled to begin slowing reimbursements to states for eligible highway, bridge, and mass transit projects.  A failure to act by Congress had the potential to slow-down or stop any number of transportation construction projects across the country in the midst of the construction season.

After volleying the bill back and forth between the chambers over the course of this week, Congress passed a final bill that ...

Posted in Financing, P3s, Policy

President Barak Obama today announced the Build America Investment Initiative (the Initiative).  According to the Fact Sheet released by the White House in advance of the announcement, the purpose of the Initiative is to increase infrastructure investment and economic growth by engaging with state and local governments and private sector investors to encourage collaboration, expand the market for public-private partnerships (PPPs) and put federal credit programs to greater use.

The transportation industry will be the first to benefit from the Initiative.

The Fact Sheet lays ...

Two measures have been introduced in the California legislature to respond to the growth of crude-by-rail volume in the state.

State Senator Fran Pavley (D-Agoura Hills) has introduced SB 1319, which would expand existing law regarding oil spills to cover inland waterways and direct the Governor to require the Administrator of the Office of Spill Prevention and Response to amend the California oil spill contingency plan to cover inland waterway spills, which would include any spills from railroads. 

Sen. Pavley told the LA Times, "We need to address the new and unique hazards of ...

Posted in Policy

The Transportation Research Board of the National Academies (TRB) has released its second volume of guidance addressing risks in project delivery, including risks associated with the National Environmental Policy Act (NEPA).  This second volume of guidance, entitled Guidance for Managing NEPA-Related and Other Risks in Project Delivery, Volume 2: Expediting NEPA Decisions and Other Practitioner Strategies for Addressing High Risk Issues in Project Delivery, (Volume 2) was submitted in March 2014 under the TRB’s National Cooperative Highway Research Program (NCHRP) and ...

Posted in Policy

On June 3, the United States Banking Committee unanimously forwarded a bill (S. 2244 the Terrorism Risk Insurance Program Reauthorization Act of 2014) that would extend the Terrorism Risk Insurance Act (or TRIA) for seven years.  The bill forwarded by the Senate Banking Committee was introduced in April by Senators Schumer (D-NY), Kirk (R-IL), Reed (D-RI), Heller (R-NV) and has 23 cosponsors.

Chairman Randy Neugebauer (R-TX) of the U.S. House of Representatives’ Financial Services Subcommittee of the Housing and Insurance Committee is pursuing a three year reauthorization.  A ...

Posted in Policy

The U.S. Department of Transportation has initiated changes to its TIGER Application review process effective for the pending TIGER VI round of funding.  The most important change is that once a project receives a technical rating, that rating will not change during the remainder of the review process.

On May 28, 2014 the U.S. Government Accountability Office (GAO) issued a report finding that in TIGER V round of funding, DOT did not document key decisions to accept and review late applications, advance projects with lower technical ratings instead of more highly-rated projects,  and ...

Posted in Policy

Posted by guest blogger William Moore.

William Moore of Vianovo works with the Transportation Transformation Group, a consortia of public and private entities that looks at ways of improving the funding and financing of the nation's transportation infrastructure, which is co-chaired by Nossaman Partner Geoffrey Yarema.

The bipartisan leadership of the Senate Environment and Public Works Committee unveiled a six-year surface transportation bill last night that would maintain current funding under MAP-21 legislation expiring in September, plus inflation. Every state would ...

Posted in Policy

On April 29, 2014, President Obama delivered a draft of "Generating Renewal, Opportunity, and Work with Accelerated Mobility, Efficiency, and Rebuilding of Infrastructure and Communities throughout America" or "GROW AMERICA" Act to Congress, promised as his administration’s proposed multi-year surface transportation reauthorization.  This is the first surface transportation authorization proposal to be released, and the House and Senate proposals are likely to be more conservative.

The GROW AMERICA Act proposes to replenish the shortfall in the Highway Trust Fund ...

Twitter Facebook LinkedIn
Tags: MAP-21, TIGER
Posted in Policy

The "Congressional Caucus on Public Private Partnerships" reconvened on April 29, 2014, inviting the installations Assistant Secretaries of the Army, Navy and Air Force to discuss how the U.S. Department of Defense ("DOD") might use public-private partnership strategies to solve installation infrastructure challenges.  Representatives Mike Rogers (R. Alabama, 3rd District) and Gerry Connolly (D. Virginia, 11th District) co-chaired.

Congressman Rogers split the discussion into three parts.  First, he asked for the panelists how P3s have solved DOD challenges in light of ...

Twitter Facebook LinkedIn
Posted in Policy

In our prior posts we noted the important changes in federal tolling law under MAP-21 and some of the issues raised by those changes.  MAP-21 modestly loosened the federal reins on tolling the nation’s Interstates and federal-aid highways.  The Obama Administration just released its federal surface transportation reauthorization legislation, the Grow America Act.  In section 1405, the Administration proposes further constructive steps to expand tolling rights, but reintroduces some constraints that MAP-21 relaxed.

Probably the most important proposal is to create the right ...

Posted in Policy

Posted by guest blogger William Moore.

William Moore of Vianovo works with the Transportation Transformation Group,  a consortia of public and private entities that looks at ways of improving the funding and financing of the nation's transportation infrastructure, which is co-chaired by Nossaman Partner Geoffrey Yarema.

Absent swift action by Congress, state departments of transportation will begin to have cash flow problems that could delay payments to vendors and slow projects.  Without action by the fall, new projects may have to be shelved until Congress can resolve the ...

Twitter Facebook LinkedIn
Tags: Policy
Posted in Policy

On Wednesday, March 5, the House Transportation and Infrastructure Special Panel on Public-Private Partnerships held a hearing entitled "Overview of Public-Private Partnerships for Highway and Transit Projects" to review the role of P3s in delivery of highway and transit projects. The witness list and links to their testimony are as follows:

Mr. Joseph Kile, Assistant Director for Microeconomic Studies, Congressional Budget Office (CBO) Written Testimony

Mr. James M. Bass, Interim Executive Director and Chief Financial Officer, Texas Department of Transportation Written ...

Posted in Policy

On February 26, President Obama announced a proposal to fund a four year surface transportation bill that would increase spending by 22% for highways and 70% for transit over current levels.  The White House provided a Fact Sheet that outlines to proposal.   The current law, the Moving Ahead for Progress in the 21st Century Act (MAP-21) expires at the end of September.  That means that a new bill or an extension must be agreed to by both Houses of Congress by that time.  The President's envisions a $302 billion four year bill that builds on the substantive provisions of MAP-21.  More ...

Posted in Policy

In a move that should make successor agencies to redevelopment agencies happy, a new law was passed and approved by the Governor on February 18, 2014 (AB 471) that, among other things, amends Section 53395.4 of the California Government Code to allow infrastructure financing districts to finance a project or portion of a project located within a redevelopment project area or former redevelopment project area.

Infrastructure financing district law now provides a mechanism to finance projects that would have otherwise been financed by redevelopment agencies but for their ...

Posted in Policy

By Ben Rubin and originally posted on the California Eminent Domain Report blog.

On July 6, 2012 President Obama signed into law MAP-21, which, among other things, contained new National Environmental Policy Act ("NEPA") requirements for the Federal Transit Administration ("FTA") and Federal Highway Administration ("FHWA").  In January 2014, pursuant to a mandate in MAP-21, FTA and FHWA adopted new regulations, which became effective this week on February 12, governing the implementation of two new categorical exclusions. The two new categorical exclusions apply to (1 ...

Posted in Policy

California Senate Bill 593 (SB 593), introduced by Senator Ted Lieu (D-Torrance), shows the interest of some State legislators in implementing performance-based infrastructure (PBI) in social programs.

SB 593 would require the California Office of Planning and Research to administer a Social Impact Partnership Pilot Program (the Pilot Program) beginning in 2015.  The Pilot Program would authorize the Director of the Office of Planning and Research (Director) to identify and submit proposed social impact partnerships to the California Legislature for its consideration each ...

Posted in Policy

House Transportation and Infrastructure Committee Chairman Bill Shuster (R-PA) and Ranking Member Nick Rahall (D-WV) announced the creation of a special committee panel to examine public-private partnerships (P3s) in the United States.  This panel will inform the Committee’s work this year on reauthorizing surface transportation programs and other legislative activity.

Committee Vice Chairman John J. Duncan, Jr. (R-TN) will serve as the Chair, while Rep. Michael Capuano (D-MA) will be the Ranking Member.  Joining them are five other Republicans - Candice Miller of ...

Posted in Policy

Posted by guest blogger William Moore.

William Moore of Vianovo works with the Transportation Transformation Group,  a consortia of public and private entities that looks at ways of improving the funding and financing of the nation's transportation infrastructure, which is co-chaired by Nossaman Partner Geoffrey Yarema.

Don’t let anyone tell you the Bipartisan Budget Agreement (BBA) enacted this week by Congress and President Barack Obama is good for transportation. The BBA rolls back the sequester of discretionary spending scheduled for 2014 and 2015 and increases ...

Twitter Facebook LinkedIn
Tags: Policy
Posted in Policy

The Congressional Public Private Partnerships (P3) Caucus held its first public event on Tuesday, November 19 in the Cannon House Office Building.  Co-chairs Reps. Mike Rogers (R-AL) and Gerald Connolly (D-VA) were joined by caucus member John Delaney (D-MD) for an hour-long discussion entitled Innovating public service delivery with P3s."  Panelists were Porter K. Wheeler, Ph.D., P3 Policy Program at George Mason University; Drew Preston, Manager, Congressional and Public Affairs, U.S. Chamber of Commerce; Matt Reiffer, Director, Transportation Programs, American Council ...

Posted in Policy

In anticipation of the US federal shutdown which occurred on October 1st, this year, the U.S. Department of Transportation (USDOT) on September 27th outlined its shutdown plan, which includes furloughs for more than 18,000 of its approximately 55,000 employees.

The various agencies within USDOT have been impacted differently by the shutdown, depending on the extent to which their activities are funded through the federal government’s annual appropriations process, which lapsed this year and resulted in the current funding gap that caused the shutdown.

The shutdown’s ...

Posted in Policy

We are now a short distance away from expiration of MAP-21, with no solution in sight for sources of funding to sustain the federal highway program.  There is no stomach in Congress to increase federal gas taxes or to make real progress toward replacing gas taxes with mileage-based user fees.

As for tolls, Rep. Bill Shuster, Chair of the House Transportation and Infrastructure Committee, said in a speech last week that they might be even more difficult to do than some of the user fees."  Tolling of interstates that have been free for decades would not be kindly received by voters, according to ...

Posted in Policy

This morning, U.S. Department of Transportation (USDOT) Secretary Anthony Foxx announced the winners of the fifth round of the Department’s highly competitive Transportation Investment Generating Economic Recovery (TIGER) discretionary grant program.  From 585 applications requesting more than $9 billion, USDOT selected 52 transportation infrastructure projects in 37 states that will receive a total of $474 million. 

Notable grants awarded today include more than $9 million to the Michigan Department of Transportation for its Kalamazoo to Dearborn passenger rail ...

Posted in Policy

Today the Federal Transit Administration published final policy guidance to augment its New and Small Starts Program final rule published earlier this year.  The final rule established how the Federal Transit Administration evaluates new major transit projects that seek assistance under these funding programs authorized by Section 5309 of Title 49, U.S. Code.  The final rule does not address changes made by the MAP-21 legislation signed last July, rather it addresses parts of the program left unchanged by the 2012 legislation.

The New and Small Starts programs were developed as the ...

Posted in Policy

Following up on our previous post regarding the uncertainty surrounding the application of Buy America requirements to utility relocations, the United States Department of Transportation (USDOT) has recently released two documents that provide further clarification on the matter.

On July 11, 2013, USDOT circulated an internal memorandum to Federal Highway Administration (FHWA) Division Administrators and the Directors of Field Services acknowledging that the broadened application of Buy America has created implementation issues for the utility industry and caused ...

Posted in Policy

Showing concern for the TIFIA JPO’s slow pace of credit approvals for major US transportation, on July 24, 2013, the Senate Committee on Environment and Public Works conducted an oversight hearing on the implementation of the TIFIA Program following MAP 21’s expansion of the program almost a year ago.  We are aware of only one project that has received credit approval in that time frame.

Geoff Yarema, a partner in the Infrastructure Practice Group and a member of the National Surface Transportation Infrastructure Financing Commission, provided testimony today at the hearing.

In ...

Posted in Policy

In addition to taking testimony from public agency project sponsors and industry leaders during the July 24, 2013 oversight hearing on TIFIA conducted by the Senate Committee on Environment and Public Works, the Committee heard from the Secretary of Transportation, Anthony Foxx, regarding the U.S. Department of Transportation’s (USDOT) implementation of the TIFIA Program since the July 6, 2012 enactment of MAP-21. 

While touting the overall success of the TIFIA program and detailing USDOT’s efforts to move projects through the TIFIA pipeline, Secretary Foxx also announced ...

Posted in Policy

In other TIFIA news . . .  

Yesterday, the TIFIA Program Office released updated TIFIA program guidance and loan document templates that purport to reflect the July 6, 2012 enactment of MAP-21.  Among other revisions, the TIFIA Program Guide has been updated to reflect MAP-21’s endorsement of a rolling application process and the imposition of specific statutory deadlines on processing applications.

While the updated TIFIA guidance documents offer welcome support to current and prospective TIFIA applicants, there appears to be at least some additional work to be done to update the ...

Posted in Policy

As we have previously reported,  the Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) recently adopted policies requiring Buy America compliance for utility relocations for federally funded transportation projects in cases where the utility performs relocation work.  On June 28, 2013, the American Association of State Highway and Transportation Officials (AASHTO), American Public Transportation Association (APTA), streetcar project sponsors, and associations representing electric, gas and broadband utilities sent a joint letter to the ...

Posted in Policy

As we have previously reported, the Federal Highway Administration (FHWA) has issued guidance holding that "Buy America applies to any utility work that is accomplished as a result of a Federal-aid highway project", unless the utility work cannot legally be reimbursed by the State.  This conclusion is based on an amendment to Buy America found in Section 1518 of MAP-21, which requires the application of Buy America to all contracts eligible for assistance within the scope of a project (as defined by the NEPA document), if at least one contract for the project is funded with Federal-aid ...

Posted in Policy

In a proposed rule to be published today, April 1, 2013, in the Federal Register, the United States Environmental Protection Agency will withdraw the numeric effluent limits for construction stormwater turbidity that the agency previously had proposed in 2009.  EPA is now proposing a rule that specifies minimum Best Management Practices (BMPs) as effluent limitations for purposes of controlling  pollutants in construction site stormwater runoff.  In general,  the rule concludes that BMP-based effluent limits constitute both a technically feasible and a cost effective way to ...

Posted in Policy

The U.S. Environmental Protection Agency (EPA) has issued a report that details funding mechanisms and development strategies that communities can use to provide innovative financing options for transit-oriented development (TOD). 

The report affirms the need for local and state transportation agencies to continue to think beyond traditional funding, procurement and contracting approaches to satisfy their burgeoning infrastructure needs. 

Detailed in the report is an explanation of innovative financing mechanisms, which should be required reading for those interested ...

Posted in Policy

On January 14, 2013, the Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) issued guidance on Section 1319 of the Moving Ahead for Progress in the 21st Century Act (MAP-21), Pub. L. 112-141, July 6, 2012.  MAP-21 is a measure that reauthorizes transportation funding through the end of 2014, and is the product of a robust effort by transportation advocates to streamline the lengthy, complex, and cumbersome federal environmental process.  As we reported here, MAP-21 includes several meaningful reforms that could expedite the National Environmental ...

Posted in Policy

State public records acts and the federal Freedom of Information Act (FOIA) were enacted to prevent favoritism and corruption, but have had unintended consequences on competition for public projects.  As discussed in a recent article, requests for information have become a vehicle for contractors to obtain valuable information about their competitors that might not otherwise be available.

In addition, requirements to disclose information about a project to the public, including information about proposals received, whether compelled by law, political pressure, or ...

Posted in Policy

The Federal Highway Administration (FHWA) released two guidance memoranda in December 2012 relating to Buy America, largely in light of the amendments made by MAP-21.  On December 20, FHWA clarified the Buy America requirements applicable to utility work on Federal-aid projects.  The December 21 memorandum provided additional amplification on FHWA’s position regarding Buy America requirements applicable to manufactured products.

FHWA’s December 20, 2012 Guidance

FHWA was in the process of evaluating the applicability of Buy America requirements to utility work on ...

Nossaman LLP’s 30-plus infrastructure attorneys offer clients, colleagues, strategic partners, and industry media a wealth of practical experience, insider insight, and thoughtful analysis here on Infra Insight. We blog about what we know best, from industry-leading procurements to local and national policy developments that affect the market and our clients.

Stay Connected

RSS RSS Feed

Categories

Archives

View All Nossaman Blogs
Jump to Page

We use cookies on this website to improve functionality, enhance performance, analyze website traffic and to enable social media features.  To learn more, please see our Privacy Policy and our Terms & Conditions for additional detail.