On behalf of state agency members, the American Association of State Highway and Transportation Officials has raised a number of concerns with the U.S. Department of Transportation about the speed and scope of its "draft national freight strategic plan."
The USDOT developed the plan in response to provisions in the 2012 surface transportation law called MAP-21, and will update and finalize it under the authority of the five-year Fixing America's Surface Transportation Act that became law in December.
The department could use the strategic plan to help guide funding decisions it makes for a new program of freight grants, and to coordinate with state DOTS on how they allocate formula funds for freight projects to fit into a national plan.
Among AASHTO's concerns were the draft plan's emphasis on improving the 65,000 highway miles of a National Multimodal Freight Network that the USDOT identified, rather than the much larger number of total road miles on which freight may move.
AASHTO also questioned the plan's heavy reliance on discretionary federal grants over traditional state-administered formula money from the Highway Trust Fund to pay for projects that bolster freight movement.
And the association repeatedly underscored that the USDOT's freight plan should recognize "the dual nature of the benefits that many investments would have on the transportation system by improving passenger and freight mobility."
For instance, AASHTO said, "the improvement of a road, bridge, or rail segment on the transportation network will likely improve both freight and passenger mobility. In almost all cases, the surface transportation network serves this dual purpose and the current draft NFSP does not give this issue adequate attention."
In the association's formal comments submitted April 25 by AASHTO President Paul Trombino – director of the Iowa DOT – AASHTO first urged federal regulators to slow a fast-moving process that aims to produce a final strategic plan by the end of July.
Since a number of state DOTs say the proposed freight network mileage does not include key freight corridors within their borders, AASHTO said that under the July timeline it is "concerned that USDOT will not be able to adequately incorporate condition assessments and performance of the National Multimodal Freight Network when it has not yet been fully identified or approved."
Instead, AASHTO urged the USDOT to "use the amount of time provided in the FAST Act to create the NFSP." In passing that law in December, Congress gave the department two years to complete a freight plan.
The association stressed that a national freight strategic plan should be flexible enough to adjust to changes in market conditions that can roil the supply chain, and leave specific requirements such as time-delay goals to a formal rulemaking process that gives all public stakeholders plenty of time to respond.
AASHTO noted that the Panama Canal will soon open its long-planned set of larger locks, with unpredictable effects on U.S. ports on the West and East coasts, along with their rail and road connections. And it pointed to the surge in Bakken oilfield production in North Dakota and Minnesota in the past 15 years, which has recently been followed by an output plunge.
Returning often to the issue of the size of a national freight network that the USDOT would target for financial support, AASHTO said the draft does not give enough consideration to local roads in urban and rural areas that often provide the first and last miles in hauling freight traffic.
AASHTO also said rural roads that handle truckloads of crops, forest or energy products and manufactured goods beyond the core highway system receive inadequate attention in the plan. It said those roads that "can be hampered by size or weight restrictions, including but not limited to during 'spring thaw,'" a period when many states limit tonnage on roads saturated by melting ice and snow.
"When aging roads and bridges cannot accommodate modern freight demands," AASHTO said, "the result can be detours of tens or even hundreds of miles for single trucks and multi-vehicle convoys. These inefficiencies result in lost time and fuel, unnecessary greenhouse gas emissions, increased costs and a reduced global competitive edge for the U.S. economy."
On the issue of how best to fund freight infrastructure investments, AASHTO said that "it is of high importance to provide a stable and predictable source of formula funding that can be used by states on all portions of the freight network, as identified through the national and/or state freight plans."
The association said the nation should use stable formula funding instead of paying for projects mainly through "discretionary grants that take extensive time to prepare for an uncertain chance of success." But it said the USDOT's "policy discussion in the draft NFSP appears to overemphasize federal discretionary grants for a limited number of high-volume facilities as the means of addressing freight project investment."
The association added: "While the draft NFSP references highway freight formula funding, AASHTO believes that the draft plan does not give adequate weight to the need for investment in the much larger multimodal national transportation system, including connections in and across rural states, and including investment made by means of federal highway formula funds apportioned to states."
It added that Congress in passing the five-year FAST Act set the pattern, and "addressed freight primarily through a new formula program, as well as through continuing longstanding formula programs." Congress also added a freight discretionary grant program, but "under the new legislation, more funding is given to freight formula funding than to freight discretionary funding."