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

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

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:

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

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.

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.

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.