AAPA Comment: FHWA s Primary Freight Network Should Include Connectors to All Trade Gateways and Freight Corridors

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1 17Jan2014 AAPA Comment - Primary Freight Network Docket FHWA AAPA Comment: FHWA s Primary Freight Network Should Include Connectors to All Trade Gateways and Freight Corridors DOT s First Strategic Objective for Economic Competitiveness: Improve the contribution of the transportation system to the Nation s productivity and economic growth by supporting strategic, multi-modal investment decisions... 1 MAP-21: The U.S. National Freight Strategic Plan shall include an identification of major trade gateways and national freight corridors that connect major population centers, trade gateways, and other major freight generators... 2 MAP-21: It is the policy of the United States to improve the condition and performance of the national freight network to ensure that the national freight network provides the foundation for the United States to compete in the global economy... 3 The American Association of Port Authorities (AAPA) welcomes the opportunity to offer comments regarding the Federal Highway Administration s (FHWA) recently-released draft map of the Primary Freight Network (PFN). 4 The 2012 transportation reauthorization bill, MAP-21, directs the Secretary of Transportation to craft a PFN by designating the highways that are most critical to the movement of freight. MAP-21 lists criteria with which FHWA, on behalf of the Secretary, should consider in forming the PFN designation, including, the origins and destinations of freight movement in the United States and land and maritime ports of entry. Based upon the Department of Transportation s FY 2014 Draft Strategic Plan and the provisions of MAP-21, AAPA recommends that FHWA take the following critical actions: 1 Department of Transportation, FY Draft Strategic Plan: Economic Competitiveness, August 20, < USC 167(f)(1)(d) 3 23 USC 167(a) 4 Designation of the Primary Freight Network, 78 Fed. Reg , Docket FHWA (November 19, 2013).

2 1. The Primary Freight Network should include last-mile connectors to all trade gateways including every seaport and all national freight corridors. Despite the Department of Transportation s longstanding recognition of the importance of intermodal freight connectors to trade gateways and freight corridors, 5 and the federal government s acknowledgment of their continuing importance for future freight movement, 6 the Federal Highway Administration (FHWA) has excluded last-mile intermodal connectors from the 27,000 mile Primary Freight Network (PFN). We believe that this decision should be reversed so that such connectors are automatically included in the PFN. Of the three components of the National Freight Network (NFN) designed by MAP- 21, all of the Interstate Highway System (IHS) will automatically be included regardless of whether any of it is designated as part of the PFN. 7 On the other hand, because a mechanism does not exist for automatically including intermodal connectors in the overall NFN, the only means for their inclusion by the federal government is their designation as parts of the PFN. For this reason non-ihs segments of the freight movement system, and in particular connectors to trade gateways and freight corridors, should be prioritized for inclusion in the PFN and then additional segments of the IHS should be added based upon relevant criteria as determined by FHWA. Trade gateways into and out of the United States and the freight corridors leading to and from them represent critical paths for American freight movement; every intermodal facility throughout the freight movement system is a critical artery where bottlenecks must be identified and resolved in order for freight to move efficiently. From discussions with FHWA staff, our understanding is that all connectors to gateways and intermodal facilities, which total approximately 1,222 miles, 8 were 5 Chimini, Lee, Caldwell, Harry. USDOT/ Federal Highway Administration. Office of Freight Management and Operations. NHS Intermodal Freight Connectors, A Report to Congress. Washington, DC, National Cooperative Highway Research Program. TRB. Intermodal Freight Connectors: Strategies for Improvement. Cambridge, Massachusetts: Cambridge Systematics, Print. (MARAD report questions whether ports will be able to meet the future challenges posed by cargo growth and international trade ) USC 167(c)(2)(b) 8 Lance Grenzeback, NCHRP Project 8-36 (Task 30): Workshop on Issues in Intermodal Connectors (Research for the AASHTO Standing Committee on Planning, 2003). < Page 2

3 excluded from the PFN because the federal government does not possess data, such as Annual Average Daily Truck Traffic (AADTT), for intermodal connectors. 9 However, FHWA does possess a more-or-less comprehensive list of National Highway System intermodal connectors provided by the states, which we believe could be used to designate connectors leading to trade gateways and freight corridors. 10 Every seaport is a trade gateway and, in the words of MAP-21, an origin and a destination of freight movement in the United States, and a maritime port[] of entry. Excluding every last-mile connector to every seaport in the 27,000-mile draft PFN strikes us as counterproductive to fulfilling the stated goal for the creation of the NFN ( to assist States in strategically directing resources toward improved system performance for efficient movement of freight on highways, including national highway system, freight intermodal connectors and aerotropolis systems ). By excluding connectors from the PFN, there will be no way for the federal government to collect data on any bottlenecks or other obstacles to freight movement into and out of gateways and other intermodal facilities within the NFN framework. 2. FHWA should change the methodology it used that resulted in a PFN weighted in favor of population centers and to the detriment of trade gateways. The methodology that the Federal Highway Administration (FHWA) employed in designating segments of the Primary Freight Network (PFN) appears to unnecessarily favor population-heavy regions to the detriment of freight network components in other, less-densely populated areas of the country. While federal law as amended by MAP-21 specifies that the National Freight Strategic Plan should identify connections to major population centers, in the same clause it also directs the Plan to identify connections to trade gateways. 11 By prioritizing population centers, unfortunately, a PFN map has been created whose route selection is weighted toward urban areas rather than a network equally devoted to trade gateways in all parts of the United States. This result is counterproductive; we therefore encourage FHWA to prioritize the routes leading to and from trade gateways for inclusion irrespective of their relationship to population so that resources may be strategically directed for freight movement efficiency. 9 Federal Highway Administration. Talking Freight Seminar An Overview of the Draft Primary Freight Network. Webinar. December 6, < 10 National Highway System: Intermodal Connectors, Federal Highway Administration. Web. December 19, < USC 167(f)(1)(d) Page 3

4 One example of the population-weighted methodology is the requirement that intermodal connectors, including those leading to trade gateways such as seaports, are only potentially included in the PFN when they are located in urban areas with populations of at least 200,000. MAP-21 does not direct the Secretary of Transportation to make such a connection between the two, and we are not aware of evidence demonstrating that a sufficient relationship exists between the critical nature of intermodal connectors to trade gateways, generally speaking, and urban areas, specifically, to warrant inclusion of intermodal connectors exclusively in this context. While we understand that the requirements of MAP-21 constrain FHWA to only 27,000 miles of centerline roadways with which to designate the PFN and we believe that the limit of 27,000 miles is insufficient for FHWA to properly complete this task FHWA nevertheless has discretion within that parameter in how it ultimately determines which roadways comprise the 27,000-mile map. After all, FHWA used two different methodologies in drafting each of the 41,000-mile and 27,000-mile maps that it released, neither of whose data-usage criteria were based upon any explicit language in MAP-21. Instead, the data selected and the ways in which it was used in designating the PFN were determined by FHWA. We believe, therefore, that FHWA has as much discretion in designating a map that has freight gateways and intermodal connectors as its centerpieces as it does in creating a map prioritizing highways through population centers. FHWA in fact used the data in two different ways in drafting the PFN so that some last-mile connectors to our country s international gateways are included in the 41,000-mile map, such as connectors between Interstate 5 and the Port of Seattle, but are excluded from the 27,000-mile map. 12 The designation of a PFN weighted in favor of population centers is a problem for land ports as well as seaports: 23 of the 24 gateways to and from the United States and Canada and Mexico do not have direct connections to the PFN. The exception appears to be Detroit, where a large population exists. An additional problem with the methodology used for crafting the PFN may stem from the prominence given to freight total tonnage and value and Average Annual Daily Truck Traffic (AADTT). By focusing on the numbers associated with truck movement, FHWA may not have taken into account the subjective importance of the types of freight being moved across the system, and instead may be focusing on consumer goods potentially to the detriment of due attention on the movement of, for example, natural resources or other types of freight critical to the American 12 Draft Highway Primary Freight Network Maps and Tables. Federal Highway Administration. Dec 12, < Page 4

5 economy. Yuma, Arizona, for example, due to its irrigation-based economy and use of the Colorado River, grows more than 80 percent of United States winter produce. 13 It is not, however, connected to the PFN in either the 27,000- or 41,000- mile iterations. The suggestion by FHWA, therefore, is that the movement of 80 percent of our country s winter produce is not critical. 3. FHWA should include all critical freight routes including this sampling of examples that have been excluded from the draft Primary Freight Network. Connections between I-110 and I-710 to the Ports of Los Angeles (LA)/Long Beach (LB), CA 30-Seaside Av./CA 29 -Ocean Bl/Gerald Desmond Bridge (6.8 miles): Waterborne customs traffic through the Ports of LA/LB tops the list in every category of the datasets used in designating the maritime-related components of the PFN, 14 but connections to them are excluded; Ports of LA/LB together comprise the largest port complex in the western hemisphere. About 35 percent (40 percent imports) of all containers move via the Ports of LA/LB. This segment connects I-110, SR 47, and I-710, which altogether carry approximately 30 percent of all U.S. waterborne container volume; The I-710/SR 710 segment is part of an on-going I-710 Corridor Project, which entails $5+ billion of improvements from Ocean Bl. to SR 60 (in the preliminary engineering and EIR/EIS phase); The Gerald Desmond Bridge/I-710 was designated a Project of National and Regional Significance in SAFETEA-LU. The Virginia Port Authority s seaport facilities, comprising the third-largest container port on the East Coast, are disconnected from the PFN because portions of Interstate 564 coupled with the 2.1-mile connection along VA-164 have been excluded from PFN designation. The connection between the Virginia Port Authority port facilities and I-81, the primary north/south freight route from Canada to I-40, is not included in the PFN. Roadway connectors to Port of New York and New Jersey facilities, which comprise the second-busiest waterborne freight gateway by value of shipments and the dollar value of international freight, are missing. These include connectors along North Avenue and Doremus Avenue from NJ Turnpike, along Port Street from I-78, and along Port Jersey Blvd to the Port Global Terminal/BMW Auto Terminal. 13 Food Technology and Agribusiness in Yuma, Greater Yuma Economic Development Corp. Accessed December 19, Web. < 14 U.S. Department of Transportation Maritime Administration (MARAD) Containers, Accessed December 19, 2013 < Page 5

6 While highways around Atlanta, Georgia a major population center appear to have been included in the PFN, gaps exist along Interstate 16, the only direct connection between Atlanta and the state s two seaports at Savannah and Brunswick. Critical connections are absent between the Port of Houston and the PFN: State Highway 146 between Port Road and State Highway 225 is a 5.8- mile roadway segment that is not included in the 27k PFN. This roadway segment handles significant freight traffic. It is the primary highway corridor to both Barbours Cut and the Bayport Container terminals, which combined handle approximately 70 percent of the U.S container trade in the Gulf of Mexico (over 6,000 trucks per day, with room for very significant terminal growth); Port Rd. is a two-mile roadway connecting the Bayport petrochemical complex, the Bayport Container Terminal, and numerous distribution centers to State Highway 146. Only the first 0.6 miles is included in the 41k PFN and all of it is excluded from the 27k PFN; Barbours Cut Blvd is a 2.5 mile roadway that connects the Barbours Cut Container terminal and numerous distribution facilities to State Highway 146. It is excluded from both the 27k and the 41k PFN. The PFN factors for consideration did not take into account Strategic Port connectors that serve National Defense as directed in the Federal-Aid Highway Act of PFN gaps in the freight routes of the commercial movement of military assets negates U.S. policy (per E.O 12656, Assignment of Emergency Preparedness Responsibilities, November 18, 1988) that sufficient capabilities at all levels of government are available to meet essential defense and civilian needs during a national security emergency. The designation of crucial freight network facilities and connectors serving Port Everglades (including sections of I-595/I-75, sections of I-95, and others) as part of the National Freight Network is incomplete and/or riddled with gaps. Port Everglades itself, located in the State of Florida and one of the nation's leading container, cruise, and petroleum ports, is also excluded from the designation. The Port is the primary storage and distribution seaport for refined petroleum product in South Florida. The majority of its cargo and petroleum product is transported via freight/truck movement. Connections to Port of Seattle terminals and rail yards have been excluded, including BNSF s Seattle International Gateway and Union Pacific s Argo rail yards, SR-519, SR-509, portions of East Marginal Way/SR-99, SR-599, the Spokane Street Corridor, Atlantic Street and West Marginal Way. Page 6

7 4. In order for the United States to remain globally competitive the Primary Freight Network and National Freight Network should reflect the multimodal nature of America s freight movement. To be competitive in the global economy, we need a national freight strategy that takes a comprehensive view of every mode of freight transportation, whether on the surface of our country or on the water, by highways and railways through the heartland or marine highways along the coasts. At present, the Federal Highway Administration s freight team has been charged by the Department of Transportation with implementing federal freight policy. We believe that this is due in part to the historically highway-focused nature of MAP-21 and its predecessors. However, in order to create a national freight strategy that is truly relevant to the 21 st Century and that accurately captures the nature of our national freight movement system, a more holistic view of freight movement must be taken. From the earliest days of our nation, there has been a clear national interest in developing and maintaining the multimodal nature of our country s freight movement system. In particular there has been a long-standing and consistent federal role in maintaining the landside and waterside connections to America s seaports and other freight gateways to our country. Strengthening America s port infrastructure and intermodal connections as parts of a National Freight Network, within a larger freight strategy, are critical to continuing America s long-term prosperity. Port-related infrastructure connecting U.S. farmers, manufacturers, and consumers to the world marketplace should necessarily be a top priority in any national freight strategy in order to enhance America s international competitiveness. All modes of freight transportation throughout our national freight-movement system are critically important. Seaports, for example, facilitate the increasing export of American-made goods that is essential to the growth of our economy and creation of jobs; cargo moving through seaports is responsible for more than 13 million jobs. Annually, the cargo activities moving through seaports generate more than $200 billion in federal, state, and local tax revenue, and more than $20 billion in Customs duties. Particularly in these challenging economic times, it is crucial that basic, core federal missions, like ensuring efficient access to America s seaports and the global economy, be recognized and prioritized. To meet the demands of 21 st Century America s freight movement, AAPA looks forward to continuing to work with the Department of Transportation on the creation of a Primary Freight Network, National Freight Network, and a national freight strategic plan. Page 7