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Comments on Interim Guidance on State Freight Plans and State Advisory Committees


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The U.S. Department of Transportation (DOT) requested comments related to the interim guidance on state freight plans and state advisory committees. In response to the Notice, the Ports-to-Plains …

The U.S. Department of Transportation (DOT) requested comments related to the interim guidance on state freight plans and state advisory committees. In response to the Notice, the Ports-to-Plains Alliance respectfully submitted these comments.

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  • 1. November 15, 2012Document Management FacilityU.S. Department of Transportation1200 New Jersey Avenue SE.Washington, DC 20590-0001RE: Interim Guidance on State Freight Plans and State Advisory Committees, Notice of Interim Guidance and Request for Comments, 77 Fed. Reg. 62596; Docket No. DOT-OST-2012-0168, October 15, 2012Dear Madam or Sir:In the referenced Notice, the U.S. Department of Transportation (DOT) requested commentsrelated to the interim guidance on state freight plans and state advisory committees. In responseto the Notice, the Ports-to-Plains Alliance respectfully submits the attached comments. Wesincerely appreciate the opportunity provided by DOT to comment and contribute on this matter.Given the importance of freight to the economy and projected growth in freight traffic, abalanced planning process is critical to modernizing our national freight transportation system,including the rural freight transportation network.Sincerely,Michael ReevesPresidentPorts-to-Plains Alliance5401 N MLK Blvd., Unit 395Lubbock, TX 79403Phone:(806) 775-3373Fax:(806) 775-3981
  • 2. COMMENTS OF THE PORTS-TO-PLAINS ALLIANCEThe Ports-to-Plains Alliance, based in Lubbock, Texas, is a non-profit, non-partisan, community-driven advocacy group led by mayors, councilpersons, economic development officials, businessand other opinion leaders from a nine-state, 2300-plus mile transportation and economicdevelopment corridor between Texas, and Alberta, Canada. Over the past decade, Ports-to-Plains Alliance members have worked successfully for critical road improvements in the nine-state Ports-to-Plains region. Today, we collaborate with our federal and state leaders, partners inCanada and Mexico, and industry partners, to deliver the infrastructure, food and fuel to secure 2
  • 3. the quality of life of Americas great cities. At the same time, we embrace Americas new energyeconomy, and are capitalizing upon wind power, biofuels and other innovation sectors to renewone of Americas greatest legacies, the rural heartland.The north-­‐south movement of goods and persons through this region relies on an existing--andoften antiquated--network of mostly two-­‐lane highways which have been designated by federallaw as National Highway System High Priority Corridors: the Ports-­‐to-­‐Plains Corridor (#38), theHeartland Expressway (#14), and the Theodore Roosevelt Expressway (#58). These existinghighways are not adequate to safely meet current and future transportation needs, especiallyfreight transportation needs, of the region and the nation. To promote economic security andprosperity throughout Americas energy and agricultural heartland, this transportation corridormust be upgraded and modernized.For this to happen—and for similar necessary improvements to be made on other rural freightcorridors—the planning process must be balanced. It is imperative that the current statewidetransportation planning process (which already covers the movement of freight) and any newfreight planning policy and process recognize the importance of the rural freight transportationnetwork and the need to maintain transportation linkages between rural and urban areas.For this reason, we respectfully suggest that the current statewide planning process, DOT’sinterim guidance on the new state freight planning process and state advisory committees, and itsimplementation of other freight and planning provisions in the Moving Ahead for Progress in the21st Century Act (MAP-21), recognize and embrace the following principles: 3
  • 4. I. RURAL TRANSPORTATION CORRIDORS ARE AN IMPORTANT PART OF THE NATIONAL FREIGHT TRANSPORTATION SYSTEM.The interconnectedness of the entire freight transportation system makes it imperative thattransportation planning not be biased between urban and rural or between modes oftransportation. Rural freight corridors bring agricultural produce from rural farms to our cities;support agricultural exports; serve the nation’s ethanol production, as well as traditional andrenewable energy industries; move freight from rural manufacturing facilities, including freightnecessary for “just in time deliveries;” are the links between urban areas, and assure reliableaccess to military bases and critical industries for homeland security. The freight planningprocess must be balanced, recognizing the important role of rural freight corridors as well ashigh-volume urban corridors.II. INTERSTATE CONNECTIVITY IS CRITICAL.Rural transportation corridors also carry freight that moves into and through the state withoutstopping. This freight is destined for other regions of the country or export. The statewide andfreight planning processes must recognize this important role of rural transportation corridors,especially federally-designated high priority corridors on the National Highway System. Theplanning processes should ensure the interstate connectivity of the national freight transportationnetwork. This network unifies our country by providing for the easy movement of people andgoods. Without it, "we would be a mere alliance of many separate parts," as PresidentEisenhower noted. The Federal Government and the states must provide the leadership and 4
  • 5. resources to help preserve and modernize the national network for the 21st century. And it allstarts with the planning process.III. THERE MUST NOT BE A BIAS AGAINST NEW CAPACITY, ESPECIALLY IN RURAL AREAS.Rural transportation corridors face a capacity crisis now and in the years ahead unless significantinvestments are made. This is especially the case in regions experiencing significant growth inenergy production. Overburdened two-lane roads are carrying more and bigger trucks than theywere designed to carry. Additional capacity is critical. The statewide and freight planningprocesses must not be biased against providing new capacity, especially in rural areas.IV. SAFETY MUST BE A PRIORITY.Highway safety, especially safety on two-lane rural freight corridor roads that often have fatalityrates well above urban interstates, must be a top priority in the planning process (in both theexisting statewide planning process and the new MAP-21 freight planning process). It isimperative that these planning processes result in adequate, targeted resources to allow theupgrading and modernizing of two-lane rural roads. This is especially the case with respect toNational Highway System high priority corridors essential to the movement of people and goodsin our rural heartland. These overburdened two-lane roads, which carry much of the food andfuel destined for our nation’s major metropolitan areas, cannot safely carry the heavy trucks andcommercial vehicles used to transport agricultural produce, energy-related commodities andequipment, and general freight. The planning process must address these safety concerns. 5
  • 6. V. ENERGY-RELATED IMPROVEMENTS ARE ESSENTIAL.In several instances, MAP-21 gives special recognition and priority to transportation facilitiesproviding “access to energy exploration, development, installation, or production areas.” Thispriority treatment should be reflected in the statewide and freight planning processes.VI. THE ABILITY OF RURAL CORRIDORS TO RELIEVE CONGESTION ON PARALLEL, HEAVILY-CONGESTED CORRIDORS SHOULD BE RECOGNIZED.Upgrading rural transportation corridors can be a cost-effective way to take pressure off ofheavily-congested parallel corridors. A good example is the Ports-to-Plains Alliance Corridor,which has the potential to help relieve congestion on the gridlocked I-35 corridor and the I-25corridor, two of the country’s most congested corridors, for a small fraction of the cost ofproviding additional capacity in the I-35 and I-25 corridors themselves. This type of analysisshould be part of the statewide planning process as well as any new freight planning process.VII. ADEQUATE BORDER INFRASTRUCTURE IS CRITICAL TO AN EFFICIENT NATIONAL FREIGHT TRANSPORTATION NETWORK.Border infrastructure is critical to promote the safe, efficient movement of goods, facilitatingtrade and supporting jobs in America. The statewide and freight planning processes should bestructured to ensure adequate, targeted resources sufficient to make the necessary investments inborder infrastructure. States should make border infrastructure a priority. The ability of U.S.businesses to compete in today’s global marketplace depends on it. 6
  • 7. VIII. MULTI-STATE ORGANIZATIONS SHOULD BE REPRESENTED ON STATE ADVISORY COMMITTEES.Given the interconnectedness of the national freight transportation system and the importance ofinterstate connectivity, organizations representing multi-state transportation corridors should bedirectly represented on the appropriate state freight advisory committees. These organizationscan help bring a regional and national perspective to the deliberations of individual state advisorycommittees. The Ports-to-Plains Alliance is a good example of this type of organization. 7