Caltrans-Comment-To-DOT-2018.Pdf
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Interim National Multimodal Freight Network – Comments California Department of Transportation (Caltrans) Division of Transportation Planning The California Department of Transportation (Caltrans) has prepared the following comments in response to the United States Department of Transportation (US DOT) Docket No. DOT-OST- 2016-0053 on the establishment of a National Multimodal Freight Network (NMFN). The attached spreadsheets include in blue color (1) all the additional designations of both routes and facilities along with the listing of 49 U.S.C. 70103(c)(2) factors, and (2) corrections to facility names and mileage. In addition, Caltrans prepared the following comments for your consideration. Caltrans urges US DOT to: 1. Envision the NMFN as a flexible network to allow States the ability to address emerging needs and to nominate and designate facilities and routes, based on continuous consultation with stakeholders and regional agencies. The limitation for each State to propose no more than 20 percent of the total mileage designated is restrictive and should be eliminated. 2. Revise the methodology to automatically include (on an ongoing basis) every current and future NHS Intermodal connectors as part of the NMFN. 3. Consider using the most current available data while developing the final NMFN; and consider additional data for comprehensive analysis as described herein. 4. Provide clarification on how to designate future facilities and routes, which may be under planning and/or project delivery stage. 5. Provide clarification on how the NMFN will be updated, frequency of updates, and the funding implications, if any, for the routes included or excluded in the NMFN. 6. Provide clarification if pipelines are treated as part of the NMFN. 7. Recognize that the Ports of Los Angeles, Long Beach, and Oakland in California are major international gateways supplying goods (on all modes) to the rest of the nation passing through many of the western states. US DOT Request on Additional Factor • Caltrans suggests adding consideration for “alternative routes in the event of major disruption”, “newly built facility/route” and “accounting for seasonal high volume routes” to the list of 12 factors being considered while establishing the Final NMFN. Caltrans Comments on Highways • Include entire Strategic Highway Network (STRAHNET) and its connectors. • Include all Tier 1, 2, and 3 networks of the California Freight Mobility Plan (CFMP) 2014, developed as a result of connectivity analysis and a collaborative statewide process. • Include routes providing access to zero- and near-zero emission fueling/charging stations as identified on the FHWA's Alternative Fuel Corridors. • Include routes providing access to truck parking and rest stops. Caltrans Comments on Railroads • Include both Class-1 railroads and 26 short line railroads operating over 6,000 miles of railroad track. • Update track mileage numbers. Page 1 of 2 Interim National Multimodal Freight Network— Comments Caltrans, Division of Transportation Planning • Include the Union Pacific Roseville (J.R. Davis) rail yard in Roseville, California, though not intermodal, which is the largest rail yard in the Western U.S. Caltrans Comments on Airports and Connectors • Airports should be determined by value and volume in addition to weight, to better reflect the economic significance of airports to the nation than tonnage. • Departing cargo weight must be added to arriving cargo weight to more accurately reflect the nation’s air cargo activity, this is particularly true for airports with substantial exports. • In addition to the five airports listed in the Interim NMFN, include the following seven airports reflecting 99 percent of California’s air cargo (by value and weight, per CFMP 2014). o Sacramento International Airport o Burbank (Bob Hope) Airport o Sacramento Mather Airport o Norman Y. Mineta San Jose International Airport o Long Beach Airport o John Wayne (Orange County) Airport o Fresno Yosemite International Airport • Include smaller and medium airports that provide much needed redundancy and help during emergencies. Caltrans Comments on Ports, Waterways and Connectors • Include all 12 deep water seaports, per CFMP 2014. • Include all waterways and the first and last mile connectors should be part of the NMFN, as they provided critical linkage of seaports and national freight system. • Include smaller to medium size ports, which help maximize global competitiveness, but experience financial challenges associated with new regulations. They provide resiliency, when larger ports are congested. Medium ports also offer a strategic point of entrance for high value perishable cargo that is unable to sustain long wait times at larger ports. Caltrans Comments on Border Crossing (both Railroads and Roadways) • Include Calexico West Port of Entry (POE) intermodal facility/border crossing as it serves railroads (though not trucks). Caltrans is aware that all freight train crossings data for the Calexico West POE is reported as data for the Calexico East POE. • Include future Otay Mesa East POE and State Route 11 intermodal facility/border crossing. Thank you for the opportunity to provide these comments. This comment letter addresses several high-level issues shared by our partners, but not all partner agencies had sufficient time to provide detailed feedback to Caltrans. Please contact Rahul Srivastava, Chief, Office of Freight Planning at (916) 651-6008 or at [email protected] for any clarifications. ATTACHMENT List of Interim NMFN (in black) with Additional Designations and Corrections (in blue) Page 2 of 2 HIGHWAY PRIMARY HIGHWAY FREIGHT SYSTEM (PHFS) ROUTES - 49 USC 70103 (b)(2)(A) Length 49 USC Data State Route No Start Point End Point Comments (Miles) 70103(c)(2) Sources CA Dillon Rd S86 I10 1.51 CA Figueroa St CA30P I110 0.17 CA I10 I405 I5 13.03 CA I10 I710 CA/AZ line 221.71 CA I105 CA3A I605 17.39 CA I110 S47 I10 20.50 CA I15 I8 CA/NV line 288.47 CA I205 I580 I5 12.96 CA I210 I5 I10 48.79 CA I210 S57 I15 21.90 Key east-west corridor from ports to the Inland Empire. Serves large scale existing & planned logistics centers. CA I215 I15 S30 S210 46.25 Designation revised to link to the new S210 extension (SBd Co) CA I238 I880 I580 2.16 CA I305 CA34P I80 0.81 CA I305 I5 S99 2.14 CA I40 I15 CA/AZ line 154.75 CA I405 I5 I5 72.52 CA I5 CA37P I8 3.21 CA I5 I805 CA/OR line 772.38 CA I580 U101 I80 13.33 CA I580 I238 I205 30.60 CA I605 I405 I210 27.46 CA I680 U101 I580 29.59 CA I710 CA29P I10 20.55 CA I780 CA40P I80 6.62 CA I8 I5 0.17 mi E S67 15.92 CA I8 S111 S7 7.14 CA I80 U101 CA/NV line 203.67 CA I805 S905 I5 26.67 CA I880 U101 I80 41.78 CA Miramar Rd I805 I15 5.15 Added "Rd" CA S11 Enrico Fermi S905 1.00 (A); (C); (D) SANDAG/CB The new Otay Mesa East (land POE) will connect to S905 via the Dr P/BTS new segment of S11. Once constructed it will provide approx 2.1 border mi of new NHS freeway & connect with a new border crossing. crossing The Rte is a critical element of the efficient flow of goods and data (value- services between CA and Baja California, as well as between CA volume) and the nation. CA S111 I8 S78 14.32 (A); (C) Truck AADT Revised to include the Brawley Bypass. Connects agricultural S78/ S86 producers & packers in Imperial & Coachella Valleys to distribution centers & consumers throughout the USA. CA S111 I8 S98 6.53 (C) Key connection between S111 & S7 where S7 leads to the international land boarder (last mile connector to the international land border) CA S118 I405 8.19 mi W 8.19 I405 CA S120 I5 S99 6.34 CA S134 I5 2.39 mi E I5 2.39 CA S14 I5 23.45 mi NE I5 23.45 CA S170 U101 I5 6.09 CA S198 I5 S99 47.80 (E); (G) Provides the only direct east-west link between S99 & I5 for the lower Central Valley from above Bakersfield to S of Merced (total distance of 140 mi) CA S22 I405 I5 9.88 Page 1 HIGHWAY PRIMARY HIGHWAY FREIGHT SYSTEM (PHFS) ROUTES - 49 USC 70103 (b)(2)(A) Length 49 USC Data State Route No Start Point End Point Comments (Miles) 70103(c)(2) Sources CA S23 U101 6.85 mi N of 6.85 U101 CA S299 U101 I5 141.40 (A); (C); (E) Critical Northern California east/west interregional, NHS, STAA Terminal Access Rte (I5 to U101) corridor that links trucking to the major north-south corridors (U101, I5, & U395). S299 links the Port of Humboldt Bay (CA’s only deep water port N of San Francisco), provides interregional movement of goods (commerce, timber, nursery, greenhouse products, dairy products, cattle, hay, pasture & range, wine grapes, forest products, colony of bees, strawberries, rice & alfalfa, livestock, potatoes, and vegetables), and it links rural communities & small urban areas across northern CA to national & international markets. CA S4 I5 S99 3.37 CA S46 U101 at S99 110.70 (E); (K) Corridor is a critical east-west interregional rte for moving Paso Robles agricultural & related products from the Central Coast (U101) to the San Joaquin Valley (I5), from local communities and agricultural processing facilities carrying products between the Central Valley and the rest of the nation via I5 and two Class I rail lines. Supports the annual movement of $7B of goods shipments between the regions, accounting for 575,000 jobs in the region. AADT Truck Traffic accounts for 20-40 % of AADT, a minimum of 4,000 trucks per day. Intermodal Connector: Serves distribution centers & intermodal facilities at intersections with BNSF Railway & UP rail mainlines, as well as first & last mile connectivity to energy production fields and pipeline facilities adjacent to the highway.