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Inside Trump 2.0's First Grant NOFO: Implications for Federal Grants in 2025
- Ryan Alcorn
- Mar 20
- 5 min read
Policy Shift Reshapes $1.5 Billion Infrastructure Grant Program
The Trump administration's January 24 amendment to the Department of Transportation's flagship infrastructure grant program signals a substantial reorientation of federal funding priorities that grantseekers must quickly adapt to. By reverting the RAISE program back to its previous BUILD designation, the administration has eliminated key Biden-era priorities on climate initiatives, equity mandates and labor provisions—transforming the competitive landscape for the program's $1.5 billion annual allocation.
This rapid policy pivot arrives amid legal challenges to several Trump administration executive orders targeting diversity programs, creating a complex regulatory environment that municipalities and other applicants must navigate. The amended notice of funding opportunity (NOFO) emphasizes traditional infrastructure metrics over the social and environmental priorities that had become central to federal grant evaluation.
For grantseekers, this transformation of a major funding source represents the first concrete example of how the administration's approach will affect the $1 trillion-plus federal grants marketplace.
A Program Shaped by Political Transitions
The infrastructure grant program has undergone multiple transformations since its inception, each reflecting the priorities of successive administrations:
Year | Program Name | Administration | Primary Focus Areas |
2009 | TIGER (Transportation Investment Generating Economic Recovery) | Obama | Economic stimulus, job creation, community recovery |
2018 | BUILD (Better Utilizing Investments to Leverage Development) | Trump (1st term) | Rural investment, streamlined process |
2021 | RAISE (Rebuilding American Infrastructure with Sustainability and Equity) | Biden | Climate resilience, equity, sustainability |
2025 | BUILD (Better Utilizing Investments to Leverage Development) | Trump (2nd term) | Infrastructure improvement, local impact |
Despite these political pivots, the program maintains consistent congressional authorization through the Infrastructure Investment and Jobs Act of 2021 (Pub. L. 117-58), securing $1.5 billion in annual funding through FY 2026.
Breaking Down the Changes
The revised BUILD program documentation reveals a significant narrowing of program objectives. While the RAISE program emphasized projects that "advance Departmental priorities of safety, equity, climate and sustainability, and workforce development," the new BUILD guidelines focus primarily on funding "eligible surface transportation projects that will have a significant local or regional impact and improve transportation infrastructure."
See the revised program description:
1. Climate Policy Rollbacks: Removing Environmental Priorities
Perhaps the most striking changes involve the systematic removal of climate-related priorities and environmental justice considerations:
Environmental Sustainability Section Redlines:
References to reducing greenhouse gas emissions eliminated
"Evidence-based climate resilience measures" removed
Language addressing "disproportionate negative environmental impacts of transportation on disadvantaged communities" deleted
While "Environmental Sustainability" remains a Merit Criteria in the program, its scope has been significantly narrowed. On page 44 of the NOFO, considerations for "legacy of racism or other systemic barriers" in environmental justice evaluations have been removed entirely.
Notably, "nature-based solutions" and "natural infrastructure" were added as criteria, but the supporting resource link (https://www.transportation.gov/priorities/climate-and-sustainability/definitions) was non-functional as of March 16.
2. Equity Framework Changes: Shifting Community Impact Evaluations
The RAISE program explicitly incorporated equity considerations through references to Executive Order 14091, "Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government." The BUILD revision has systematically removed these references:
Equity Section Redlines:
"Equity considerations for underserved communities"
Partnerships with "disadvantaged businesses (8a)"
References to "diverse" workforce development initiatives
The BUILD program no longer explicitly prioritizes projects that "proactively evaluate whether a project will create proportional impacts to all populations in a project area and increase equitable access to project benefits."
3. Labor and Workforce Development Changes
While workforce development remains a consideration, specific language promoting partnerships with unions and emphasis on job quality has been removed:
Labor Section Redlines:
Mentions of partnerships with "local unions"
Language emphasizing "high-quality jobs with the free and fair choice to join a union"
References to workforce development now focus more broadly on job creation rather than specific quality metrics or labor agreements.
4. Active Transportation De-emphasis
The BUILD revision reduces emphasis on non-motorized transportation options:
Active Transportation Redlines:
Projects that "improve public health by adding new facilities that promote walking, biking, and other forms of active transportation"
Several references to multimodal transportation priorities that specifically highlighted pedestrian and cycling infrastructure
Navigating Legal Complexities
The rapid transition between administrations has created a complex legal environment for infrastructure grant applicants. Several executive orders issued in January 2025 aimed at limiting diversity, equity, and inclusion programs have been partially blocked by court injunctions and are being appealed.
Legal Caveat: As of March 16, 2025, federal courts have issued preliminary injunctions affecting the implementation of certain executive orders related to federal grant programs. These rulings create a fluid legal situation that may impact how DOT evaluates BUILD applications. Applicants should consult with legal counsel to determine how these injunctions may affect specific application components.
The New Funding Playbook
This redlined FY 2025 BUILD NOFO rolls back much of the explicit climate, environmental justice, and equity language seen in the last few years—returning the grant to a style reminiscent of earlier BUILD or TIGER rounds. Instead, the new NOFO focuses on:
Traditional Infrastructure Objectives: Emphasizing physical capital projects in areas such as safety, freight mobility, and state-of-good-repair.
Less Prescriptive Requirements: No references to Justice40 or specialized workforce programs that characterized the Biden-era RAISE grants.
Straightforward Civil Rights Compliance: The framework underscores nondiscrimination and "merit-based opportunity," with fewer explicit tie-ins to "underserved communities" or "disadvantaged business enterprise (DBE) participation."
Conventional Cost-Effectiveness Approach: The structure (SF-424, BCA, etc.) remains, but lacks prescriptive climate and equity performance metrics.
Recommendations for Future Applicants
Despite the legal uncertainties, applicants can take several concrete steps to optimize their BUILD applications under the new criteria:
Emphasize Local Economic Impact: Quantify job creation, tax base expansion, and improved freight efficiency with hard numbers rather than qualitative assessments.
Highlight Traditional Infrastructure Improvements: Center applications on conventional metrics like reduced congestion, improved safety, and extended facility lifespans.
Reframe Environmental Benefits: While sustainability remains a criterion, focus on infrastructure durability against natural hazards rather than climate change mitigation.
Broaden Community Benefit Language: Replace targeted equity language with demonstrations of how projects benefit entire communities, including disadvantaged areas as part of broader impacts.
Maintain Thorough Documentation: For any equity or climate components that remain in applications, maintain clear documentation of their relevance to core infrastructure improvement goals.
The Road Ahead
The BUILD program amendments likely foreshadow similar changes across the federal grant ecosystem. Grantseekers should anticipate:
Additional NOFOs revised to reflect similar priority shifts
Changes to reporting requirements on existing grants
New emphasis on traditional economic metrics across agencies
For organizations with long-term grant strategies, developing politically resilient applications that can withstand administrative transitions has become essential. Successful grantseekers will balance adherence to current priorities with fundamental project merits that transcend political cycles.
The infrastructure grant program's evolution demonstrates that while administrations may change program emphasis, congressional authorizations maintain the underlying funding. Grantseekers who can adapt their narratives while maintaining focus on fundamental infrastructure improvements will continue to succeed in this shifting landscape.
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