OneRail Comments on USDOT Proposed State Freight Plan Guidance

Release Date: 
Nov 15 2012

November 15, 2012 WASHINGTON DC - The OneRail Coalition submitted comments in response to the USDOT's proposed State Frieght Plan Guidance today. The comments are included below and also attached at the bottom of the page.

 

Before the

United States Department of Transportation

Office of the Secretary of Transportation

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Docket Number DOT-OST-2012-0168

Interim Guidance on State Freight Plans and State Freight Advisory Committees

http://www.gpo.gov/fdsys/pkg/FR-2012-10-15/pdf/2012-25261.pdf

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Comments from the

OneRail Coalition

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The OneRail Coalition is pleased to submit comments in response to the United States Department of Transportation's (USDOT) Proposed State Freight Plan Guidance.

 

About the OneRail Coalition:

 

 

 

Members of the OneRail Coalition (OneRail) include freight rail, passenger rail, rail transit, rail supplier, rail labor, and environmental organizations who seek to increase public and private investment in the nation's rail infrastructure to enhance mobility, economic competitiveness, and job creation, as well as to meet the energy and environmental challenges of the 21st century.

Integrating Rail into State Freight Plans:

The efficient movement of freight in the United States depends on a well-functioning multi-modal system, including truck, rail, water, air, and pipeline modes. According to the most recent Commodity Flow Survey, rail has a 40.2% share of the nation's freight ton-miles. Given this reality, it is crucial that State Freight Plans fully integrate rail and that State Freight Advisory Committees fully integrate railroad representatives, railroad employee representatives, and freight rail industry experts.

Because of rail's inherent characteristics and efficiencies, the full inclusion of freight rail into State Freight Plans will help States and the USDOT address the USDOT's strategic goals of improving safety, state of good repair, livability, and environmental sustainability. Increasing the share of freight that moves by rail will also alleviate highway congestion, help insulate the cost of freight movement from the volatility of gas prices, and help reduce the country's dependence on foreign oil.

And due to the privately owned and maintained nature of the vast majority of the country's freight rail network, policies and planning that encourage the growth of freight rail will frequently be the most cost efficient choice for both state and federal governments that are operating in an era of constrained resources. Increasing the share of freight moved by rail is beneficial and cost-effective to shippers as well.

Especially with regards to particularly heavy loads, the transportation of freight by rail will allow States to avoid the deterioration of roadways and the extraordinary expenses associated with repairing or mitigating that damage.

With regards to the content of State Freight Plans, the inventorying of State Freight Transportation Assets, and the analysis of the Conditions and Performance of the State's Freight Transportation System, OneRail recommends that the guidance recommend to States to make particular note of the aspects of the freight system that play a disproportionately important role in enabling the efficient functioning of the whole freight network. For instance, while all highway sections that carry freight are important, the sections of the highway that lead directly into and out of major intermodal freight facilities are of particular importance. As States consider the designation of the 27,000 mile highway freight network, OneRail recommends that the USDOT encourage States to prioritize the highway infrastructure that would best support the intermodal freight rail network. By focusing on these crucial intermodal connectors, States will be able to most effectively target their investments and leverage scarce resources.

It is important to note that domestic intermodal freight has been growing steadily, and the railroads' significant investments in intermodal facilities and line capacity are making the shift from truck to rail even more attractive for shippers.  OneRail encourages the USDOT to emphasize to the States the growing trend toward domestic intermodal and the opportunities for rail to increase its market share of freight moving between 500 and 2,000 miles as illustrated on the chart below, sourced from the 2007 Commodity Flow Survey and the 2007 Rail Carload Waybill Sample:

Truck and Rail Intermodal Share in Markets 500 miles or greater

Mileage Blocks

Truck (Millions of Units)

Rail Intermodal (Millions of Units)

Total Market (Millions of Units)

Truck Share % (Millions of Units)

Rail Share %

500-749 miles

17.8

1.2

19.0

94%

6%

750-999

10.1

2.3

12.4

82%

18%

1,000-1,499

7.7

2.0

9.7

79%

21%

1,500-2,000

3.7

2.1

5.8

63%

37%

2,000+

2.8

4.9

7.7

36%

64%

Total

42.1

12.5

54.6

77%

23%

Source: 2007 Commodity Flow Survey; 2007 Rail Carload Waybill Sample

OneRail commends the USDOT for specifically noting that "private infrastructure owners, such as railroads" and "organizations representing the freight industry workforce" should be included on State Freight Advisory Committees.  OneRail recommends that the railroad representatives, railroad employee representatives, and freight rail industry experts be included in the development of freight plan options and that the Advisory Committees be balanced in their composition.

OneRail also appreciates the listing of a selection of Rail Freight Resources and Statistics for use by the States in their freight planning process. However, OneRail encourages the USDOT to be even more explicit that, while any cooperation would of course be voluntary, States should consider the freight railroads to be a crucial resource in their planning process. While they will be unable to share proprietary or competitive information, the railroads will be a valuable source of information to States on rail market trends, performance measures, the types of traffic that can best be moved by rail, intermodal bottlenecks, issues regarding the location and construction of intermodal facilities, improving intermodal efficiency, etc. OneRail also believes that there may be additional freight rail resources and statistics available in the marketplace towards which the USDOT could direct States. Between the railroads themselves, the major rail industry trade associations, and third party research reports such as those from Cambridge Systematics and various financial analysts, additional data and analysis regarding future freight rail trends that would be useful to State Freight planners may be available. The DOT might consider purchasing publicly available data on behalf of the States for their freight planning efforts.

Integrating Freight into other State Transportation Plans:

Beyond the issue of ensuring the full integration of rail into State freight planning efforts, it is also crucial that freight in general be fully integrated into States' overall transportation planning efforts. Again, OneRail commends the USDOT's Interim Guidance on State Freight Plans and State Freight Advisory Committees for encouraging States to integrate their State Freight Plans with both their Statewide Long-Range Transportation Plans and their State Rail Plans. This will allow State Freight Plans to most effectively guide State decision making and resource allocation, in addition to helping States meet the national freight goals of the soon-to-be-developed multi-modal National Freight Strategic Plan and the National Freight Policy established in 23 U.S.C. 167.

Sections II (Policy) and IV (Contents of State Freight Plans) of the State Freight Plan Guidance asks States to incorporate freight provisions from their State Rail Plans into their Freight Plans and identify private transportation infrastructure owners such as railroads in their discussion of the State's strategic goals for freight transportation.  One Rail supports this type of comprehensive planning and consistency across transportation plans. OneRail notes that any additional detail or guidance that can be provided by USDOT to States about how to integrate these various plans would be useful.

States should be encouraged to form multi-state planning groups to address freight moving in multi-state corridors. These groups should include freight rail, as well as other modes. Freight rail corridors such as the National Gateway, Crescent Corridor, and Heartland Corridor are prime examples of successful private/public partnerships that are achieving an increase in freight rail volumes and efficiency, and a market share shift of freight from publicly funded highways to privately funded freight rail networks.