North Dakota Departlllent of Transportation

Transcription

1 North Dakota Departlllent of Transportaton Grant Lev, FE. Drector Jack Dalrymple Govemor September 2, 2016 Docket Management Faclty US Department of Transportaton 1200 New Jersey Avenue SE W Washngton, DC DOCKET NO. DOT-OST ; ESTABLISHMENT OF INTERIM NATIONAL MULTIMODAL FREIGHT NETWORK (NMFN) The North Dakota Department of Transportaton (NDDOT) takes ths opportunty to express ts sgnfcant concerns wth the Interm Natonal Multmodal Freght Network (NMFN) set forth n ths docket. As explaned more fully below, the route mleage wthn North Dakota on the Interm NMFN s nadequate to meet the needs for a connected transportaton system that serves Interstate freght transportaton movng n and through our state. In makng ts fnal desgnaton n ths docket, USDOT must very substantally ncrease route mleage on the NMFN wthn North Dakota. At the outset, NDDOT emphaszes that t fully supports the comments that t submtted jontly wth four other state DOTs. That submsson, by the 5-State Coalton group of Idaho, Montana, North Dakota, South Dakota, and Wyomng, lays out mportant reasons why the fnal NMFN must nclude far more mles than the Interm NMFN, partcularly ncludng hghway mles. AASHTO has fled comments wth smlar concerns and we are also supportve of AASHTO's comments to ths docket. Those flngs present USDOT wth a framework of reasons as to why t should, n makng a fnal NMFN desgnaton, very substantally ncrease route mleage on the NMFN-ncludng wthn North Dakota. In ths separate submsson, the NDDOT sets forth ts specfc recommendatons for the NMFN wthn North Dakota. More specfcally, USDOT's proposed NMFN contans nadequate mles on the roadway system to effcently and effectvely operate as an ntegral part of the NMFN. Ths especally s true for the western one-half of the Unted States. For example, from 1-29 n Eastern North Dakota to the next transnatonal north/south route, whch s n Western Montana, there s a dstance of approxmately 670 mles, as the crow fles. Ths would requre trucks from the rch ol felds n Western North Dakota to travel a dstance of approxmately 335 mles (or about 5 hours) east or west to connect to the next north/south NMFN route. To expect our freght ndustry-and the Naton's economyto routnely accept ths amount of ndrecton s smply unacceptable. For ths and other reasons, North Dakota s requestng the followng hghway-mode routes be added to the NMFN: 1. We request that the entre Longer Combnaton Vehcle (LCV) network (the Natonal Network) wthn North Dakota be added to the NMFN. Ths would allow freght to move 608 East Boulevard Avenue Bsmarck, North Dakota Informaton: NDROADS ( ) FAX: (701) TTY: 711

2 Docket No. DOT-OST Page 2 September 2,2016 along already dentfed corrdors to best serve the people of the Unted States. (See enclosed map, Hghway Mode Opton 1.) Such desgnaton would be fully consstent wth the factors set forth n 49 USC (c)(2). Such desgnaton also furthers the polces set forth n the subparagraphs of (c)(2) regardng access to energy and agrcultural and natural resource products and facltes. Consstent wth 49 USC (c)(2), these routes also promote connectvty and faster goods movement. 2. If the USDOT determnes that t wll not add the entre LCV system wthn North Dakota to ts Interm NMFN, as a mnmum we request the followng routes be added. (See enclosed map, Hghway Mode Opton 2.) As wth desgnaton of the LCV network n our state dscussed mmedately above, these desgnatons would be fully consstent wth the factors set forth n 49 USC (c)(2). Such desgnatons also further the polces set forth n the subparagraphs of (c)(2) regardng access to energy and agrcultural and natural resource products and facltes. Consstent wth 49 USC (c)(2), these routes also promote connectvty and faster goods movement. a. US 2 - from the Montana State Lne to US 52. US 2 s a major East/West corrdor that runs from Washngton State to the Upper Pennsula of Mchgan. The porton proposed to be added n North Dakota runs from the Montana State lne east to Mnot nto the newly constructed ntermodal faclty whch lnks the BNSF Ralroad and the Canadan Pacfc Ralroad to sea ports on both the East and West coasts of the Unted States, as well as ports n Canada; addtonally, t connects to US 52 provdng access nto Canada. US 2 s also a vtal lnk for Montana, Wyomng, and parts of South Dakota to connect to the ntermodal faclty n Mnot. b. US 85 - from the South Dakota State Lne north to US 2. US 85 s part of the Ports to Plans Corrdor whch runs from the very southern tp of Texas near the Mexcan Border all the way north to Canada. The porton n North Dakota that we are requestng to be added to the System tes nto US 2 near Wllston, North Dakota, whch s the heart of the Baaken Ol Felds. US 2 leads drectly nto Mnot, whch recently constructed an ntermodal faclty whch lnks the BNSF Ralroad and the Canadan Pacfc Ralroad to sea ports on both the East and West coasts of the Unted States, as well as ports n Canada. US 85 s a vtal route for freght to flow nto the Baaken Ol Felds, whch s the 2 nd largest producer of ol n the Unted States. A lot of the supples used n the Baaken come from the Mnot ntermodal faclty whch were shpped from other parts of the world. US 2 s also a vtal lnk for Montana, Wyomng, and parts of South Dakota to connect to the ntermodal faclty n Mnot. Ths route s also part of a congressonally desgnated hgh prorty corrdor. c. US 83 - from the South Dakota State Lne north to US 2. US 83 runs from the very southern tp of Texas near the Mexcan Border all the way north to Canada. The porton n North Dakota that we are requestng to be added to the System tes nto Mnot, whch recently constructed an ntermodal faclty whch lnks the BNSF Ralroad and the Canadan Pacfc Ralroad to Sea Ports on both the East and West Coasts of the Unted States, as well as ports n Canada. US 83 s a vtal route for freght to flow nto the Mnot ntermodal faclty so t can be shpped to other parts of the world.

3 Docket No. DOT-OST Page 3 September 2,2016 d. US from the South Dakota State Lne north to US 281 runs from the very southern tp of Texas near the Mexcan Border all the way north to Canada. The porton n North Dakota that we are requestng to be added to the System goes thru Jamestown, North Dakota, whch s only a few mles from the Sprtwood Energy Park, whch s home to major energy and other manufacturng producers. US 281 also tes nto US 52 whch goes drectly nto Mnot, whch recently constructed an ntermodal faclty whch lnks the BNSF Ralroad and the Canadan Pacfc Ralroad to Sea Ports on both the East and West Coasts of the Unted States, as well as ports n Canada. US 281 s a vtal route for freght to flow nto the Mnot ntermodal faclty so t can be shpped to other parts of the world. e. US 52 - from 1-94 to US 2. US 52 s a drect connecton from 1-94 near Jamestown nto Mnot, whch recently constructed an ntermodal faclty whch lnks the BNSF Ralroad and the Canadan Pacfc Ralroad to Sea Ports on both the East and West Coasts of the Unted States, as well as ports n Canada. US 52 s a vtal route for freght to flow nto the Mnot ntermodal faclty so t can be shpped to other parts of the world. f. US 2 - from the Mnnesota State Lne to US 2 s a major EastlWest corrdor that runs from Washngton State to the Upper Pennsula of Mchgan. The porton proposed to be added connects US 2 n Mnnesota to the porton already proposed by USDOT to be on the Interm Natonal Multmodal Freght Network n North Dakota. g. US 12 - from the South Dakota State Lne to the Montana State Lne. US 12 s a major connector route for Montana and South Dakota. h. Hghway from US 85 to the Montana State Lne. Hghway 200 s a major connector route for Montana to the Baaken Ol Felds n North Dakota and the ntermodal faclty n Mnot. Each of these routes proposed to be added has a drect connecton to our surroundng states and provdes a lnk to the recently constructed ntermodal faclty n Mnot. Ths ntermodal faclty provdes better freght connectons to the surroundng states. The next closest ntermodal faclty s located ether n St. Paul, Mnnesota, to the east (a dstance of over 500 mles) or Spokane, Washngton, to the west (a dstance of over 900 mles). The Mnot faclty s strategcally placed close to one-half way between the two facltes and wll draw freght, ncludng but not lmted to energy, agrcultural, and natural resource products and supples for ther extracton, from the surroundng states-whch wll n return utlze the routes dentfed n our request. As noted n the FAST Act, freght movement s a multmodal endeavor. As such, NDDOT coordnated wth the short lne ralroads operatng n the state of North Dakota to determne prorty routes that should be added to the NMFN. Whle Class 1 ralroads playa vtal role n long-dstance movement of freght by ral, short lne ralroads n North Dakota provde the crtcal servce of consoldatng feld to market truck-hauled agrcultural and energy commodtes for ultmate long-dstance transport by the Class 1 ralroads. Wthout ths consoldaton (and opposte-drecton, supply-sde dstrbuton) of products, the Naton's producton of commodty goods could not functon effcently and effectvely. Therefore, t s crtcal that the followng short lne ral routes be added to the NMFN, as shown on the enclosed ral-mode map: a. Northern Plans Ralroad's entre system n North Dakota;

4 Docket No. DOT -OST Page 4 September 2,2016 b. Red Rver Valley and Western Ralroad's entre system, except for ts Woodworth to Pngree and Chaffee to near Durbn routes; c. Dakota Mssour Valley and Western Ralroad's entre system n North Dakota. Each of these systems provde long-dstance ral connecton servces to energy and/or agrcultural shuttle facltes vtal to the economy of the state of North Dakota and the Naton's food and energy supply chans. Rural states such as ours provde a lfelne for the entre Unted States. It s the rural states that provde a majorty of the food that not only feeds the Unted States but much of the world. North Dakota s the number one producer of 12 crops, most of whch are transported to other states or countres for consumpton. All of these commodtes travel by truck before they arrve at ther fnal destnaton; many of them are then consoldated and transported by short lne ralroads. All of the proposed addtons (both hghway and short lne ral modes) serve major agrcultural producng areas n the state. By not havng such addtonal routes on the NMFN, the Unted States may lose our compettveness wth other countres. In addton to beng the number one producer n 12 crops, North Dakota s also the number two producer of ol n the Unted States. Many of the supples the ol ndustry uses to operate on a daly bass arrve by truck and/or short lne ral. It s essental that the NMFN provdes for ths ndustry to reman compettve wth the rest of the world. In addton to the above specfc recommendatons for route addtons, we also urge that USDOT provde, n desgnatng the fnal NMFN, that any crtcal rural or urban freght corrdors desgnated pursuant to 23 USC 167 are automatcally added to the NMFN, even f they are desgnated pursuant to 23 USC 167 after USDOT publshes a map of routes and facltes on the fnal NMFN. In proposng these addtons to the Interm NMFN wthn our state, we note our concern that some may consder that there are lmts on what a state may propose to add to the NMFN. We dsagree. We strongly dsagree wth any nterpretaton by USDOT that mposes greater lmtatons on what a state government may propose to add to the NMFN than t mposes on others commentng to ths docket. Also as to state submssons to ths docket, to the extent USDOT consders t necessary, we certfy that we have satsfed the requrements that a state s to certfy pursuant to 49 USC (c)(4)(D). In concluson, we strongly encourage you to adopt our recommendatons and addtons to the NMFN. To the extent you consder not adoptng these recommendatons, we ask that before makng a fnal decson contrary to our recommendatons, you contact us to dscuss the desgnatons wthn our State. We thank you for the opportunty to provde these comments and thank USDOT for ts consderaton. )!)~. GRANT LEVI, P.E., DIRECTOR 56/sss/sas Enclosures

5 NATIONAL MULTI-MODAL FREIGHT NETWORK (NMFN) - HIGHWAY MODE OPTION 1 w*' N S 16) r GOLDEN VALLEY; BILLINGS " ~~~.-~g-b~~medora._._.l._._._._. _.-._.-._._"-'-'-' 'L r _ _ _ _._._. BURLEIGH 14 '-1 ;:) I U I ;:)MJ-I.I'I : DICKINSON' I 16 BISMARCK -( :,-- - J j_._._._.._._._._._._._. /ss 81] LAMOURE Notce of Dsclamer The North Dakota Department of Transportaton (NODOl) makes ths map avalable on an ~as s bass as a publc servce. Under no crcumstances does NDDOT warrant or certfy the nformaton to be free of errors or defcences of any knd. NDDOT specfcally dsclams all warrantes. express or Impled, ncludng but not lmted to the warrantes of merchantablty and ftness for a partcular purpose. F:\PLANNING\Steve_Nelson\MXOS\2016\NMFT _OPTION 1_F ACILlTY(rev mxd RAIL SHUTTLE FACILITY USDOT PROPOSED NMFM HIGHWAY MODE NDDOT PROPOSED NMFN HIGHWAY MODE ADDITIONS STATE OF NORTH DAKOTA NORTH DAKOTA OEPARTMENTOF TRANSPORTATION PLANNING I ASSET MANAGEMENT DIVISION U.S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION 2016

6 NATIONAL MULTI-MODAL FREIGHT NETWORK (NMFN) - HIGHWAY MODE OPTION 2 w.' N s I~}-'-'-'- ' r'-' GOLDEN: VALLEY; fl6, ;,, I :9-4,-._._._..:.. '85 BILLINGS EDORA ; fl85 I, BOWMAN -"-"-"-_0._.. -- Notce of Dsclamer The North Dakota Department of Transportaton (NODOl) makes ths map avalable on an "as Is bass as a publc servce. Under no crcumstances does NODOT warrant or certfy the nformaton to be free of errors or defcences of any knd. NODOT specfcally dsclams all warrantes. express or mpled,ncludng but not lmted 10 the warrantes of merchantablty an,d ftness for a partcular purpose. F:\PLANNING\Steve_Ne!son\MXDS\2016\NMFT _ OPTlON2_FACILITlES(rev 90116).mxd RAIL SHUTTLE FACILITY USDOT PROPOSED NMFM HIGHWAY MODE NDDOT PROPOSED NMFN HIGHWAY MODE ADDITIONS STATE OF NORTH DAKOTA NORTH DAKOTA DEPARTMENT OF TRANSPORTATION PlANNING I ASSeT MANAGEMENT DIVISION U.S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION 2016

7 NATIONAL MULTI-MODAL FREIGHT NETWORK (NMFN) - RAIL MODE w.' N s Notce of Dsclame r The North Dakota Department of Transportalon (NODOl) makes ths map avalable on an "as s bass as a publc servce, Under no crcumstances does NDDOT warrant or certfy the nformatlon to be free of errors or defcences of any knd. NODOT specfcally dsclams au wa rrantes. express or mpled,ncludng but not lmted to the warrantes of merchantablty and ftness for a partcular purpose. F:IPLANNINGlSteve_NelsonIMXDS\2016INMFT _ OPTlON2_FACILITlES_RAILROAD PROPOSED.mxd RAIL SHUTTLE FACILITY USDOT PROPOSED NMFN RAIL MODE NDDOT PROPOSED NMFN RAIL MODE ADDITIONS STATE OF NORTH DAKOTA NORTH DAKOTA DEPARTMENT OF TRANSPORTATION PLANNINGJ ASS ET MANAGEMENT DIVISION U.S. OEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION 2016