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.

1. November 15, 2012
Document Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE.
Washington, DC 20590-0001
RE: 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, 2012
Dear Madam or Sir:
In the referenced Notice, 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 submits the attached comments. We
sincerely 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, a
balanced planning process is critical to modernizing our national freight transportation system,
including the rural freight transportation network.
Sincerely,
Michael Reeves
President
Ports-to-Plains Alliance
5401 N MLK Blvd., Unit 395
Lubbock, TX 79403
Phone:(806) 775-3373
Fax:(806) 775-3981

2. COMMENTS OF THE PORTS-TO-PLAINS ALLIANCE
The 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, business
and other opinion leaders from a nine-state, 2300-plus mile transportation and economic
development 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 in
Canada and Mexico, and industry partners, to deliver the infrastructure, food and fuel to secure
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3. the quality of life of America's great cities. At the same time, we embrace America's new energy
economy, and are capitalizing upon wind power, biofuels and other innovation sectors to renew
one of America's greatest legacies, the rural heartland.
The north-­‐south movement of goods and persons through this region relies on an existing--and
often antiquated--network of mostly two-­‐lane highways which have been designated by federal
law as National Highway System High Priority Corridors: the Ports-­‐to-­‐Plains Corridor (#38), the
Heartland Expressway (#14), and the Theodore Roosevelt Expressway (#58). These existing
highways are not adequate to safely meet current and future transportation needs, especially
freight transportation needs, of the region and the nation. To promote economic security and
prosperity throughout America's energy and agricultural heartland, this transportation corridor
must be upgraded and modernized.
For this to happen—and for similar necessary improvements to be made on other rural freight
corridors—the planning process must be balanced. It is imperative that the current statewide
transportation planning process (which already covers the movement of freight) and any new
freight planning policy and process recognize the importance of the rural freight transportation
network 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’s
interim guidance on the new state freight planning process and state advisory committees, and its
implementation of other freight and planning provisions in the Moving Ahead for Progress in the
21st Century Act (MAP-21), recognize and embrace the following principles:
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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 that
transportation planning not be biased between urban and rural or between modes of
transportation. 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 and
renewable energy industries; move freight from rural manufacturing facilities, including freight
necessary for “just in time deliveries;” are the links between urban areas, and assure reliable
access to military bases and critical industries for homeland security. The freight planning
process must be balanced, recognizing the important role of rural freight corridors as well as
high-volume urban corridors.
II. INTERSTATE CONNECTIVITY IS CRITICAL.
Rural transportation corridors also carry freight that moves into and through the state without
stopping. This freight is destined for other regions of the country or export. The statewide and
freight planning processes must recognize this important role of rural transportation corridors,
especially federally-designated high priority corridors on the National Highway System. The
planning processes should ensure the interstate connectivity of the national freight transportation
network. This network unifies our country by providing for the easy movement of people and
goods. Without it, "we would be a mere alliance of many separate parts," as President
Eisenhower noted. The Federal Government and the states must provide the leadership and
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5. resources to help preserve and modernize the national network for the 21st century. And it all
starts 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 significant
investments are made. This is especially the case in regions experiencing significant growth in
energy production. Overburdened two-lane roads are carrying more and bigger trucks than they
were designed to carry. Additional capacity is critical. The statewide and freight planning
processes 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 fatality
rates well above urban interstates, must be a top priority in the planning process (in both the
existing statewide planning process and the new MAP-21 freight planning process). It is
imperative that these planning processes result in adequate, targeted resources to allow the
upgrading and modernizing of two-lane rural roads. This is especially the case with respect to
National Highway System high priority corridors essential to the movement of people and goods
in our rural heartland. These overburdened two-lane roads, which carry much of the food and
fuel destined for our nation’s major metropolitan areas, cannot safely carry the heavy trucks and
commercial vehicles used to transport agricultural produce, energy-related commodities and
equipment, and general freight. The planning process must address these safety concerns.
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6. V. ENERGY-RELATED IMPROVEMENTS ARE ESSENTIAL.
In several instances, MAP-21 gives special recognition and priority to transportation facilities
providing “access to energy exploration, development, installation, or production areas.” This
priority 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 of
heavily-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-25
corridor, two of the country’s most congested corridors, for a small fraction of the cost of
providing additional capacity in the I-35 and I-25 corridors themselves. This type of analysis
should 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, facilitating
trade and supporting jobs in America. The statewide and freight planning processes should be
structured to ensure adequate, targeted resources sufficient to make the necessary investments in
border infrastructure. States should make border infrastructure a priority. The ability of U.S.
businesses to compete in today’s global marketplace depends on it.
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7. VIII. MULTI-STATE ORGANIZATIONS SHOULD BE REPRESENTED ON STATE
ADVISORY COMMITTEES.
Given the interconnectedness of the national freight transportation system and the importance of
interstate connectivity, organizations representing multi-state transportation corridors should be
directly represented on the appropriate state freight advisory committees. These organizations
can help bring a regional and national perspective to the deliberations of individual state advisory
committees. The Ports-to-Plains Alliance is a good example of this type of organization.
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