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FHWA/FTA AGUADILLA LRTP JOINT AGENCY COMMENTS November 2, 2011

Page/Section Comment PRHTA Response (September Nov 2, 2011 Federal Nov 23, 2011 Federal Agency 2011) Agency Response Response General Comments Please verify the Table of Table of contents verified. Accepted Contents for titles, section numbers, and appendices 1 The titles on the tables Tables identified by 2031 year Accepted throughout the plan need to horizon as applicable. be specifically identified. PR is revising currently 7 Plans, 2/3/2012 Federal Team: Please ensure any general reference to the publication date on the document cover or within, is correctly identified 2031 plans without as February 2012 – or the final date specifically identify the LRTP after it has been reviewed by the being reviewed will cause public, amd then adopted by the MPO. confusion. The document still retains the “November 2011” date. 2 Please ensure the final Done Accepted document has been edited for grammar, spelling as well as consistency in format and acronym usage.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 1 3 Congestion Management Plan Sentence included at Chapter 5, Please include the full Congestion page 59. Management Process in the - please provide a sentence in appendices (it was not in the draft we your CMP chapter that the full received) and identify in Chapter 5 report is found in the which appendix that is.. appendix of this document PRHTA Response: Congestion and incorporate. Management Process was included in Appendix D, as requested. Chapter five mentions and refers to Appendix D.

2/3/2012 - Federal Team – accepted with the understanding it will be fully incorporated in the 2040 Plan 4 Maps of the municipalities of This question appears to be for Accepted the Arecibo UZA Plan not the the Arecibo North Region one for Aguadilla. need to be included. At times the write is confusing as to whether Barceloneta is separate or a part of the Arecibo UZA. As you read along they explain it. But this should be clear from the beginning.

5 Please check the first It is revised to be consistent with Accepted the Projection tables C-1 and C-2 paragraph under Section 6.1.9 Forecast Growth in Federal Funds- part of this sentence appears to be a fragment form a prior version (regarding fiscal year 2010)

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 2 6 Table 4.4 Section 4.2.2 – the Done Accepted projects are in Spanish, please translate to English.

7 Table 4-5 and Table 4-6 – Done Accepted these tables are in Spanish, please translate to English

8 Table 4-6 and 4-7 – As agreed, we are doing the Please include all the same as with the 2030 San Juan transit related projects, Transit -PRHTA addressed this and Intermediate and Long Range UA Plan, with the proportion including project added Transit funding for short, – all the projects list the same applicable to Aguadilla (in the identification, costs, and intermediate and long term funding. funding level – will the bridge absence of a model run for the funding sources, and Accepted replacement projects cost as 2031 plan). other projects that are much as the roadside being considered as part pavement markings? Will of the development of a the intermediate projects and system wide/regional the long term costs remain transit system (e.g., the same over these years? nonmotorized projects). The LRTP cannot consist of strictly highway related projects. 23 CFR 450.322 requires that the LRTP contain long range and short range strategies/actions/invest ments that lead to the development of an integrated multimodal transportation system. The lack of these projects makes it impossible to demonstrate that the LRTP is fiscally constrained, since it does not provide costs and

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 3 revenues for the missing projects. PRHTA: See Appendix C, Table C-3A, as well as project tables in Chapter 4. 9 Tables 4-5, 4-6 and 4-7 These are region-wide projects, It is important for not Islandwide. The last version transparency to the The agencies would like to offer a should list projects specific to of the AUALRTP we submitted public, that the proportion suggestion for how this can be the Aguadilla TMA, and not for review included regionwide of these lump sum illustrated by adding the following 8 island wide. How much of projects. projects that will be line table that is the sum of the 20 the lump sum projects will be specifically for the years: dedicated specifically to this The description says Aguadilla region be area? “Islandwide”. because it is the identified. Additionally 20 Year total for Island Wide name of the lumpsum project. are these projects 20 year total for San Juan However, the column with the intended to use federal 20 year total for Aguadilla heading “Municipality” and the funds? As was done with 20 year total for South UZA cost column refer to the region the San Juan LRTP, please 20 year total for North UZA (“regionwide”). It has also been identify the Aguadilla 20 Year total for East UZA accepted thus for purposes of portion in these tables. 20 Year total for Southeast UZA the TIP and STIP. 20 Year total for Southwest UZA Response: The Aguadilla Area-specific lump sum Total costs of the Plan projects are identified as recommendations in each UZA and “Region Wide” among TMA should match the revenues those that are expected to be going to that area. A intermediate- and long- table is needed to demonstrate this. range. Those projects identified as Islandwide PRHTA Reponse: See newTable C-4 in are lump sum projects Appendix C of the Aguadila LRTP. that cover thewhole of Puerto Rico and the 2/3/2012 – Federal Team: accepted portion specific to Aguadilla may not have . been defined yet (once defined, they will be

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 4 presented as such).

10 We need to be in agreement Yes We agree. It is our understanding that that PRHTA is using the PIP for the 2040 plans a new that was updated for the comprehensive Public Participation SJUZA. However, they are Process will be developed and used. simultaneously working on a And that PIP /PPP will be prepared in accordance with SAFETEA-LU PIP document that will be one requirements, which calls for a 45 day PIP for all planning processes. public review of the draft PIP/PPP before it is finalized.

11 The PR State Natural Yes, as part of the regular In the 2040 Long Range Plans the Resource Dept. should have project development process, state environmental agencies will need given comments as to the the DRNA was consulted. to be more involved and protection of the 3-4 State documentation of that collaboration Forests in this region. As well will need to be included in the Plans. as the noted “Magotes” that should have a policy for conserving them.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 5 Yes. Accepted 12. 2031-2040 LRTP - Comment: All tables and charts have been re-titled to reflect the 2031 horizon

13. List of Projects short, Comment: I did not find and That is correct. Please include all transit Please identify where the narrative projects and any other discussion is located that identified the intermediate, and long range tables showing transit projects that are being corridors where transit investment is projects in the short, considered as part of the needed – consistent with the maps. intermediate or long term…..I development of a system Additionally Please identify where in only saw roads and bridges wide/regional system. the document the narrative connects for FHWA. The LRTP cannot consist the planned projects for the network of strictly highway related mapped in figure 2-2 and the costs and projects. 23 CFR revenues identified in the appendices. 450.322 requires that the And, if such a narrative does not exist, LRTP contain long range it needs to be prepared and included. and short range The FHWA network corridor description strategies/actions/invest can be used in mirroring the transit ments that lead to the network. development of an integrated multimodal Please correct the title to figure 2-2 to transportation system. make it consistent as 2031 The lack of these projects speaks directly to the PRHTA Response: question about the fiscal constraint, or lack The narrative mentioning a conceptual thereof, of this Plan. transit plan suggesting an express Include an explanation of intercommunity service is at the regional transit Section2.2: Strategies for Public system planned in the Transportation in Aguadilla TMA (page future which will include a 20). This is further developed at transit system for the for Section 4.1.3.1 Public Transportation Aguadilla UZA which Network at page 41, and in the includes the Bike system Recommendation section in page 45.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 6 that crosses At Section 4.1.3.1, although it focuses municipalities such as for on the publicos’ service, it also Rincon, Isabela, mentions the corridor. Aguadilla, Etc. A norther Region Transit System A brief explanation was added to the that begins in Bayamon narrative in order to refer how the and ends in Camuy or conceptual Transit Plan shown at figure Hatillo which is so close to 2.2 was considered in current projects Camuy… as follows (page 20): “Figure 2.2 Response: See tables in suggests an alignment for this Chapter 4 of the revised intercommunity express service 2031 LRTP, as well as through the median of the PR-2. This is Table C-3 and C-3A in at a conceptual stage and needs Appendix C. further analysis. Thus, this alternative is not included at this point, as part of cost feasible projects mentioned in Chapter 4.” Aguadilla TMA Transit network is characterized mainly by públicos’ routes at this point. The reference to transit network and services throughout the AUA considers this particular situation and the fact the regional Airport brings about other factors in terms of visitors and freight needs that have to be addressed. Nevertheless, AUA considers transit as a definite possibility for the area due to the activity generated, although currently there are not funds identified. Furthermore, FTA annual allocations for the region are addressed toward the policy defined in the plan for the region incentivizing and promoting local transit routes, and other initiatives.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 7 The figure 2.2 title was corrected to make it consistent as 2031 as well as figure 2.3.

2/3/2012 – Federal Team: changes accepted

Yes. It is our understanding so Please insert narrative that outlines the 14.Highy Project Tables Do the short term and far, that the short term and transit strategic improvements using intermediate tables show all intermediate tables in the the format in Section 4.1.4.2 that was anticipated highway projects Aguadilla LRTP show all used for the highway improvements. that will need to be amended anticipated highway projects into the STIP and the TIP for that will need to be amended PRHTA Response: Although the the period between the into the TIP and the STIP for the recommended transit corridor is adoption of the 2031 and the period between the adoption of mentioned throughout the discussion 2040 Plan adoption? the 2031 LRTP and the adoption of the transportation network, at page of the 2040 LRTP. In fact, some 45 Section 4.1.4.1 was added the of these projects have already following suing the referred format: been included in the TIP and STIP, and do not require “ The following key transit project is amendment, while others may recommended for the ATMA: be included as part of a new TIP and STIP, once the LRTPs are  Express Transit Service. An adopted. Thus, they may not express transit service is proposed necessarily require amendments to connect urban centers throughout for inclusion. the island, and part of that system will serve the Aguadilla region. It will link Aguadilla to Arecibo, Mayagüez, San Juan, Ponce, and other urban areas, connecting to público terminals or transit centers in each community (figure 2.2). The objective is to offer an island wide

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 8 inter-urban service that is similar to the interurban train and bus service that operated throughout the island in the past. The economic growth in the region with the expansion of the Rafael Hernández airport in 2005 had generated and increase in passenger movement in almost 50%. This transit corridor would connect these activities and the mobility of the academic community in the University of Puerto Rico, Mayaguez Campus, representing a population of approximately 15,000 students and staff traveling from municipalities around the island. Nevertheless, further studies are required to estimate ridership and route alignment.” 2/3/2012 – Federal Team: Accepted

Not yet. Accepted 15. Bridge Replacement Are there any critical bridge replacement projects that need to be included in the listing of Cost Feasible projects?

16. A final breakdown of the Comment: Table C-1 Island Thank you. Accepted revenues and expenditures wide Revenues - FTA is good specific for AUZA. See Chapter with the island wide VI Tables C

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 9 The average actual toll price is Please include this Please indicate what financial analysis 17. Toll Revenues Question: It is observed that tolls revenue appear to $0.60 approximately. We have discussion in the text and studies support this forecast rather continue to increase for every projected increases in this narrative in Chapter 6 to than statingit was based on the year until 2031. Can the source of revenues based on support the basis of these projections of the consultant. public sustain these projections made by our assumptions and as an RESPONSE: WE SUGGEST TO MAKE THE consistent increases. Is it consultant, which are very important component of FOLLOWING CHANGES TO CHAPTER 6: realistic? What is the price for conservative. The increases in demonstrating that the "The average actual toll price is $0.60 toll today and what the price Tolls revenues have been LRTP is fiscally projected to end up as for the established in less than 2% constrained. approximately. We have projected public. annually, which is consider increases in this source of revenues sustainable. Most of these Response: Please see new based on a regression analysis, using increases are due to the next to last paragraph in fiscal years from 1999 to 2011. The elimination of the 5% discount in section 6.1.8 of the regression analysis considered the Auto- Expreso, more traffic and revised 2031 Aguadilla average toll price, the real personal a slight increase in the average LRTP. income, and the gasoline price, among toll price up to $0.64 in 2016. other factors. Based on this, the increases in Toll revenues have been established in less than 2% annually, which is considered conservative and sustainable. Most of these increases are due to the elimination of the 5-cent discount in "Auto- Expreso" (e-pass), more traffic, and a slight increase in the average toll price of up to $0.64 in 2016. This represents additional revenues of approximately $4.0 million annually."

2/3/2012 Federal team: Accepted

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 10 The Toll revenues projection are Please include this See comment above – what type of 18. Toll Revenues We too are concerned about the projected toll revenues considered conservative and discussion in the text analysis was performed that the and whether or not growth realistic. The increases in Toll narrative in Chapter 6 to projection was based upon? Revenues (less than 2%) support the basis of these estimate for this revenue RESPONSE: Same as above. stream is realistic. If there is basically comes from the assumptions and as an information that you can elimination of the 5% discount important component of provide to support this on Auto-Expreso, which demonstrating that the assumption, please include represents an additional LRTP is fiscally 2/3/2012- Federal team: Accepted that information in Chapter 6. revenue of approximately $4M constrained. annually. This explanation has been included in Section 6.1.8 of Response: Again, please Chapter 6. see new next to last paragraph in section 6.1.8 of the revised 2031 Aguadilla LRTP.

19.. Toll Revenues FHWA: Chapter 6 Toll When we prepared this Please include this Accepted Revenues: Currently the document, the most recent data discussion in the text information only provides was for the year 2009, due to narrative in Chapter 6 to projected revenues vs. real 2010 Audited Financial support the basis of these revenues through 2009. Statements were issued during assumptions and as an There should be at least one the March 2011. Thus, we important component of more real year data for this considered to keep 2009 demonstrating that the and a projected level for the numbers as the latest actual LRTP is fiscally rest of the life of the 2031 information to be consistent with constrained. plan. Additionally, there is the information presented in the the statement in the San Juan LRTP. The Table 6-1 Response: Again, please document that actual toll (page 65) shows a decreased in see section 6.1.8 of the receipts have been lower tolls revenues and Figure 6-5 revised 2031 Aguadilla than projected. This (Page 71) shows that the actual LRTP. information within Chapter 6

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 11 needs to be updated as well tolls revenues are less than as toll revenues in Table C-1 previous projection. However, historically the tolls revenues have been consistently increased, except for year 2008 and 2009 which the decreases were due to: 1) Decrease in Traffic due to slowdown in the economy, 2) 5% Discount offered to Autoexpreso users, and 3) Reclassification of Prepaid amounts as Deferred Revenues. This is explain in more detail in Section 6.1.3 (Page 71).

20.FTA Revenues FTA: Why are the revenues The revenues from FHWA have Please include more text Accepted been increasing $5M every year, narrative to support this for FTA and FHWA consistent but for conservative purpose we methodology and the throughout the 2010 -2031: projected a slight increase in uncertainties related to FHWA $127,050,000 million this figure. Regarding the the future Federal and FTA $12, 0000 million. revenues from FTA, we allocations, including any considered only the amount that adjustments for inflation. the PRHTA received for the TrenUrbano operation, which is Response: Please see new $12M annually. next to last paragraph in section 6.1.9 of the revised 2031 Aguadilla LRTP.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 12 21. Expenditure Table C2 - FTA: Question: Why do you The actual Table C-2 presents Please make Table 6-5 consistent with just one ARRA Expenditures for the appendices tables in regards to Island wide have ARRA expenditure FTA and the other one is for ARRA. Is Table 6-5 a revenue table or amounts for FTA 2 times on FHWA. We separated the an expenditure table? Please clarify. your table for capital amount of ARRA funds to be expenditures Island wide received from FTA and FHWA to PRHTA Response: See revised Table 6- 2010-2031 clearly identify the purpose of 5, which is a revenue table. these funds. 2/3/2012 – Federal team: Accepted 22. ARRA Funds FHWA: in Chapter 6 section We have corrected Section 6.1.9 Table 6.5 Federal Funding: Still are not 6.1.9 it states that the ARRA to clarify that the ARRA funds clear if this table is for revenues funds will be exhausted by will be exhausted by 2014, since because of the footnote that states the Fiscal Year 2012, why under the ARRA Implementing 2013-15 are expenditures. The Title of does Table C-1 Revenues Guidance available to PRHTA, this table should be clarified and show ARRA funds in 2013 and which was updated in April of remove the 2013-2015 funds that are 2014? 2009, it is stated that spending really expenditures in the FTA ARRA for ARRA projects could extend column. to September 30, 2015. The delay on these projects are PRHTA Response: See previous basically due to weather and response (number 21). site conditions, as well as permits approvals and other contingencies matters. 2/3/2012 – Federal Team: accepted

23. ARRA Funds FTA: In Table C-2 As mentioned in the previous Accepted Expenditures – is it necessary comment, the ARRA for them to carry out the Implementing Guidance ARRA funding (reflect in the available to PRHTA stated that tables) after year 2014. spending for ARRA projects could be extended to September 30, 2015. The delay on these

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 13 projects are basically due to weather and site conditions, as well as permits approvals and other contingencies matters.

24. ARRA Funds FHWA: we agree FHWA: In We corrected Chapter 6 of the Accepted Chapter 6 section 6.1.9 it LRTP to properly mention that states that the ARRA funds the ARRA funds will be used will be exhausted by the until fiscal year 2014. These Fiscal Year 2012, why does ARRA projects experience Table C-2 Expenditures show certain delays due to weather Construction Federal ARRA and site conditions, as well as funds in 2013 and 2014? permits approvals, and other contingencies matters.

25. Revenues Proportionate FTA: It was observed that The FTA funds was fixed at Please include more text Accepted for Aguadilla 2010 - 2031 your revenues for FHWA $12M annually for Island Wide narrative to support this Table C1A C2A continue to grow throughout (Table C-1), which represents methodology for the the planning years till 2031. the amount received for Mass development of the Why are the FTA Funds held Transportation. The amount funding level and the at $16,220,000 +/- till F2031? presented in Aguadilla LRTP is uncertainties related to the corresponding proportion of the future FTA federal that revenues to this region. allocations, including any adjustments for inflation.

Response: Please, see tables C-1 and C-3 and notes in Appendix C of the revised 2031 Aguadilla LRTP.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 14 26. Revenue Tables FTA: Please provide a title to We made the correction, the Accepted name of the Table is "Table C-2 the Table Revenues for A: Aguadilla Urbanized Area Aguadilla 2010-2031 Revenues Proportion".

27. Table C2-A FTA: Please title your blue We made the correction, the Accepted name of the Table is "Table C-2 The C2A table for A: Aguadilla Urbanized Area expenditures for Aguadilla Expenditures Proportion". specifically.

28. Table C2-A FTA: Table C2A should Presentation corrected in Table Yes, but the tables use The AUA proportion was inadvertently C-2 A. different time frames. left off the C-2A table for years 2025 provide a total for all funding Tables C-1 and C-2 break through 2031. at the bottom of the tables. down the information by Currently, it has been omitted year. The C-2A tables PRHTA Response: Accepted and break down the revised. information by a consistent period of 2/3/2012 – Federal Team: Accepted. years. Please use one or the other method for all the tables to ensure all the tables are consistently formatted and presenting the information to the reader

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 15 in the same manner.

Response: Please see format changes in tables included in Appendix C of the revised 2031 Aguadilla LRTP.

29. 2040 Plans FTA Comment: Perhaps in the We will modify this presentation Accepted in the 2040 Plan to be consistent 2011-2040 Plans to make it with the presentation made for easier on the PRHTA in the the San Juan LRTP. development of the remaining plans that rather than prepare tables that are broken out year to the 20 year horizon, that perhaps they can provide a breakout the first 5 years and the group the remaining years by every 5 years.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 16 30. Tables C1A-C2-A FHWA: TableC1A and C-2A Our revenue proportion Please provide more Changes, if made, to section 6.1.3 methodology is based on the clarification and narrative were not clearly identifiable and need Aguadilla Revenue Proportion assumption that all revenues are on this. It is necessary to to address this concern regarding - In the previous round of considered Island Wide not to a be clear to the reader whether toll revenues are being used comments it was asked that specific region, and then it is how the allocations for on non-tolled facilities. the Chapter 6 include allocated to the region based on the funding are made and discussion on Toll Revenues the project costs for that specific any related uncertainties. RESPONSE: The PRHTA uses the toll (projected and real) for the region. Thus, even there is no revenues as stated in Section 129 to Aguadilla area. The tolls in Aguadilla region, we Additionally, there are properly maintain the toll facilities response from PRHTA was assigned the corresponding toll specific requirements and around the island. Any excess should that “There are no toll revenues based on the project mandates on how Section be used as addressed in same Section revenues specifically in this costs in this area as per the CIP. 129 revenues are used. It 129. Also, the total dedicated is possible that the non- area.” Yet, table C-1A revenues backed the payment tolled facilities in 2/3/2012 – Federal Team: accepted includes toll revenues (as well of the Bonds issued for projects Aguadilla may or may not as fines) for Aguadilla. around the island, including qualify for use of those Please clarify this Aguadilla Region. revenues. It should be inconsistency. clarified that this is not an issue.

Response: Please see toll revenue discussions in sections 6.1.3 and 6.1.8 of the revised 2031 Aguadilla LRTP.

31. 2010 - 2031 PIP for FTA Comment: Madeline Whatever, public involvement process There may have been a the PRTHA is currently using should be Aguadilla and UZA Muniz explained that a misunderstanding, since there is attached, and a statement must be specific Public Involvement no new PIP for the 2031 and provided that the Public Involvement Program has been developed 2031 LRTPs. A PIP is being Process this LRTP specifically geared to for the 2010-2031AUZA, as developed for all areas as part this Plan. However, for the 2040 LRTP well as for the smaller UZA’s of the 2040 plan. a Comprehensive Public Involvement LRTP. It is a specific PIP Plan will be developed to incorporate

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 17 Program for the 2010-2030 most public involvement processes. UZA that can be amended to 2/3/2012 –Federal team: Accepted for the PIP Plan that was used in this Plan with the understanding that the 2010-2040 SJUZA the full Public Involvement process will appendix. be updated that includes documented outreach efforts will be made for the 2040 plan update 32. For the 2011-2040 LRTPS A revised Public Involvement There was none. See previous Same as above response. Plan concurrently is being developed as one public involvement plan incorporating all the planning process and comments periods such as LRTPs, UPWP, STIP/TIPS, Amendments, Revisions, etc. However, in order to get the AUZA and smaller UZA LRTP out as soon as possible a separate updated Public Involvement Program was revised only for these 2031 LRTP updates.

33. Concurrently, the PIP for the The second part of the comment Same as above 2040 Plans will be one Public is not clear (incomplete Involvement Plan incorporating sentence?). See previous all of the planning process and responses. In response to our public comment periods: Public interpretation of the comments for LRTP Reviews, PIP comment/question, the current Reviews, STIP, TIP, UPWP , PIP includes the updating amendments, revisions etc. This process for the LRTP. will be captured as one document for the 2040 plans.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 18 However, for the sake of completing the AUZA and smaller UZAs LRTP a Public Involvement Program strictly providing guidance on the LRTPs.?

34. Aguadilla Model - PRHTA is FTA comment: FTA 2040 LRTP for Aguadilla and San Please note: it is Accepted developing a new model for the Juan will be SAFETEA-LU understood by the federal AUZA understands that PRHTA will compliant regarding the travel partners that a thorough be developing a new Travel demand forecasting. review and modification Demand Model for Aguadilla of the model used for the UZA, as per Mr. Luis 2031 Plan was not made Rodriguez’s letter on May 24, and that the 2040 Plans 2011. when adopted in 2012 will be fully compliant in methods used to forecast demand.

Response: Yes, this is understood. 35. Aguadilla Model FTA Comment: will the new Yes. It includes all regional UZAs Please note: it is Accepted and TMAs. understood by the federal Voyager 2 model be used for partners that a thorough all the regional UZA for 2040 review and modification or just Aguadilla UZA of the model used for the 2031 Plan was not made and that the 2040 Plans when adopted in 2012 will be fully compliant in methods used to forecast demand. Response: Yes, this is understood. 7.

FHWA-FTA Joint Agency Comments (November 2, 2011) Page 19 FHWA-FTA Joint Agency Comments (November 2, 2011) Page 20

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