Many of you have reviewed the Department of Transportation's request for information regarding the new ROUTES Initiative sent by IRPT today. Further, many of you have noticed that the ROUTES Initiative is to be coordinated by Federal Highway, Federal Transit, Federal Rail and Federal Aviation Administrations. IRPT believes that Maritime Administration should be included as a coordinating agency.
Please take a moment to review IRPT’s response below to the request for information. You can also view the letter in .pdf format here.
December 8, 2019
Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
West Building Ground Floor
Washington, DC 20590-0001
Re: Request for Information, Docket number: DOT-OST-2019-016
Inland Rivers Ports & Terminals Association, Inc. (IRPT) writes to request that the Department of Transportation consider the inclusion of Maritime Administration’s Office of Ports and Waterways in the ROUTES Council and Infrastructure Management Team.
The primary focus of our inland ports is to grow our economies by providing an access point for multi and inter modal transport via river, rail and road. An efficient intermodal freight network is vital to both domestic and international commerce of the U.S. and its contributions to the integrated freight network.
Many of the nation’s exports are generated along the inland river system and the imports are destined for locations along or connected to the inland river system via road or rail.
America’s maritime transportation system is comprised of a multitude of ports and terminals along approximately 24,000 commercially navigable miles of inland and intra-coastal waterways and channels that moves domestic and international cargo. With a few exceptions, most inland and small coastal public ports are located within rural areas of the country. Even more, for every public port, there are hundreds of private terminals located within rural areas as well.
Rural Opportunities to Use Transportation for Economic Success (ROUTES) is an initiative to address disparities in rural transportation infrastructure. Our nation’s freight transportation backbone, its ability to survive and compete globally depends as heavily on America’s inland and small coastal ports and terminals as on its large coastal ports and harbors. Specifically, rural transportation infrastructure’s unique challenges need to be considered in order to meet our Nation’s priority transportation goals of safety and economic competitiveness. Maintaining the maritime transportation system so that its performance is reliable, cost-effective, and environmentally sustainable, is a key challenge within the context of competing federal priorities and limited resources.
The proposed ROUTES Initiative will be coordinated across key modal administrations, including the Federal Highway Administration (FHWA), the Federal Transit Administration (FTA), the Federal Rail Administration (FRA), and Federal Aviation Administration (FAA). Another important partner that should be included is the Maritime Administration, the agency responsible for America's waterborne transportation system. The Maritime Administration supports the technical aspects of America's maritime transportation infrastructure, including port and vessel operations, national security, environment, and safety.
To ensure our Nation has the safest, most efficient, and modern transportation system in the world, all modes of transportation, including river, road and rail should be considered. Input for the ROUTES Council and Infrastructure Management Teams should be included from agencies who oversee all modes, including Maritime Administration.
Rural transportation networks are critically important for domestic uses and export of agriculture, mining, and energy commodities, as well as the quality of life for all Americans. America’s maritime facilities are an important component of our nation’s overall freight transportation system, especially for transporting bulk commodities, such as coal, petroleum, chemicals and grain. However, rural networks face unique challenges in safety, infrastructure condition, and usage. Commonly acknowledged challenges include:
- Inland and small coastal ports and terminals have been, and continue to be, neglected in terms of discretionary funding opportunities, especially when compared to other transportation modes.
- Presently there are only limited funding opportunities, such as the BUILD and INFRA programs, that make inland and small coastal port infrastructure eligible for funding at all, and only a very small percentage of total funding from those programs typically fund port-type projects. Inland and small coastal port and terminal facilities cannot compete effectively against large highway projects for funding, and most individual projects cannot meet the $5 million project minimum required by current programs. Infrastructure projects sought by inland and small coastal port and terminal facilities are typically far less costly than the minimum required for those programs, but funding opportunities for these facilities are much less available.
- Due to limited funding opportunities, inland and small coastal port and terminal facilities are forced to compete for the same funding resources against other transportation modes, against coastal seaports, and against each other.
Inland and small coastal port and terminal facilities are nationally significant assets of great value that need to be recognized as important regional supply chain modes, especially when considering the commerce and economic development provided by the aggregate, and merit one or more dedicated sources of discretionary funding.
Addressing Unmet Needs Through DOT Discretionary Grant Programs:
- Historically, any federal assistance to the inland river ports and terminals has been appropriated through Maritime Administration, Department of Transportation. In the Consolidated Appropriations Act of 2019 signed on February 14th, Maritime Administration’s budget was funded at over $1 Billion, with only $7 million directed spending towards inland ports, through the Marine Highways Program. Even further, that $7 million does NOT extend to bulk commodities (liquid or bulk), unless it is a “new service.”
Even more disturbing is that a new Port Infrastructure Development Program included in the appropriations bill excludes inland ports, more specifically, it states: “projects eligible for funding provided under this heading shall be projects for coastal seaports.”
Simply stated, Inland ports and terminals are NOT on a level-playing field in terms of federal funding opportunities
The solution presented herein by IRPT is specific dedicated funding, by way of, a percentage of existing program funding (INFRA, TIGER, BUILD, etc.) OR a standalone discretionary grant program dedicated to the many inland private and public facilities that serve the nation’s freight transportation needs. For far too long, appropriation bills such as INFRA and BUILD programs and authorizing legislation like the FAST Act and WRDA have underfunded inland facilities. Additionally, inland facilities cannot compete for funding in INFRA, BUILD, TIGER, etc. because the project minimum is far too high. Infrastructure projects sought by inland facilities are far less costly than the minimum required for those programs, but the composite result provided by potentially funding these projects could be exponentially beneficial to the nation’s transportation network.
IRPT is requesting Congress introduce/pass/authorize an Inland Port and Terminal Grant Program to level the competitive playing field. Mirrored much like the small shipyard grant program, the inland port and terminal program would:
- Be administered by Maritime Administration;
- Adhere to 60-day submission and 120-day award distribution;
- Include both private and public facilities;
At the same time, the inland port and terminal program would differ from small shipyards in that:
- Funds may be used to construct buildings, physical facilities, purchase equipment, etc.
- May be used for landside infrastructure (facility river, road and rail) projects
And unlike the Marine Highways program, the inland port and terminal grant program would:
- Extend to both private and public entities;
- May be used for landside infrastructure (facility river, road and rail) projects;
- Extend to bulk (liquid and dry) commodities;
The Advocate: Inland Rivers Ports & Terminals, Inc. (IRPT): is a non-profit trade association with nearly 300 members nationwide. IRPT advocates for the inland waterways and the industries and companies that serve and utilize our inland rivers, ports and terminals. IRPT and its members welcome Federal Agency and Congressional partnership and pledge to offer their support, organizational resources, and network to aid in achieving long-term sustainability through infrastructure investment.
- Most of the discretionary grant programs for federal funding assistance currently require a public sponsor, yet many of the facilities moving the nation’s freight are not located within a public port or are located with rural areas with smaller staffed city/county administration. It is difficult and challenging at best for private terminals to secure a public sponsor in order to be eligible for federal funding assistance.
In some cases, securing a public sponsor means that the sponsor must spend their time and resources to administer the grant, perform audits, etc. With many of the terminals being located in rural areas, it is difficult for the sponsor to extend their resources without monetary compensation.
Should the nation’s private terminal facilities fail to meet infrastructure investments assisted by federal funding opportunities, the waterborne cargo diversion that would take place would cause truck traffic to nearly double, two inches of asphalt would be needed to increase the pavement thickness to 126,000 lane-miles to intercity Interstate systems. Increased truck traffic significantly increases fuel consumption and emissions and increases maintenance costs on surface transportation.
It is therefore, a benefit to the general public in terms of safety, environment and cost savings for surface transportation rehabilitation to allow private terminal facilities to be eligible for federal funding assistance. Federal funding assistance has historically extended to private facilities (without a public sponsor) in the following programs:
- Railroad Rehabilitation & Improvement Financing (RRIF)
- Clean Diesel National Grants
- Consolidated Rail Infrastructure and Safety Improvements (CRISI)
- Small Shipyard Grant Program
If the goal of the ROUTES initiative is to improve how the DOT considers rural project applications in DOT's discretionary grant and credit programs, IRPT believes it is imperative to consider the many ports and terminals moving the nations freight located within the rural communities. Providing rural communities with technical assistance for meeting the Nation's transportation infrastructure investment needs, calls for Maritime Administration’s Office of Ports and Waterways to serve on the ROUTES Council and Infrastructure Management Team in a capacity to serve rural maritime communities.
In 2016, U.S. DOT released their draft “National Freight Strategic Plan (NFSP)” calling for a greater focus on future of U.S. freight movement. IRPT would like to share the following observations:
- The Multimodal freight network map was created with the intent that DOT create a freight network that encompasses not only highways, but also the local roads, railways, navigable waterways, and pipelines, key seaports, airports, and intermodal facilities necessary for the efficient and safe movement of freight in our country.
- As described in the DOT press release, the “draft MFN map is to inform planners, stakeholders and the public about where major freight flows occur and where special attention to freight issues may be most warranted”. The original draft MFN map had only shown 2 inland ports on the Mississippi River – St. Louis and Memphis and showing no ports for the following rivers: Missouri, Arkansas, or Red. The updated interim maps are only slightly better as many inland ports are still not listed.
- The explained methodology used for the NSFP was in part, acquired by the U.S. Army Corps Waterborne Commerce Statistics Center (WCSC), using only 78 ports of the 360 commercial ports where major intermodal transfer of cargo occurs. As of November, 2019, there are only 303 currently recognized by WCSC and many still remain unrecognized. Since October 20th of 2016 when DOT issued the federal register notice announcing the NFSP, IRPT has taken many strides to update the Waterborne Commerce Statistics Center’s data for inclusion in future initiatives, such as the newly formed ROUTES Initiative. More specifically, thanks to the dedication of IRPT, we have been successful in getting additional ports recognized.
As of September 11, 2019, the Department of Transportation still only recognizes very few inland ports, yet there are hundreds of ports and many more private terminals that are carrying the nations freight. As you can see in the table below (simply abbreviate to show a few states), DOT recognizes only a fraction of ports and no private terminals.
|State||Number of Ports Recognized on Interim National Multimodal Freight Network Maps||Actual Number of Ports||Actual Number of Terminals|
IRPT is concerned that if the contents of the ROUTES Initiative is similar to the NFSP, it will not recognize our inland port and terminal facilities as the transportation facilities helping move the countries cargo. Including Maritime Administration’s Office of Ports and Waterways to the ROUTES Council and Infrastructure Management Team will allow for the needs of the maritime communities be brought forth.
IRPT commends you for your strong focus on freight transportation, as the efficient and safe movement of freight is vital to the U.S. economy. IRPT would greatly appreciate your consideration of the inclusion of Maritime Administration in the ROUTES Council and Infrastructure Management Team, even more specifically, the Office of Ports and Waterways within Maritime Administration. Please do not hesitate to contact me if I can be of any assistance.