The Intermodal Association of North America is recommending that the U.S. Department of Transportation include freight intermodal connectors — roads that link ports, airports and railroad terminals to main highways — as part of the nation's Primary Freight Network (PFN).
The DOT's Federal Highway Administration has issued a draft proposal for designating 27,000 miles of centerline highway as the primary freight corridors, as required by Congress in the 2012 MAP-21 transportation bill, and now plans to review input from industry stakeholders and other members of the public. The deadline for commenting on the freight network designation was Feb. 15.
The designation is part of developing a first-ever national freight strategy as part of a holistic transportation strategy. Taking inventory of corridors that handle the most inter-regional traffic is expected to help policymakers set priorities on where to invest scarce federal resources for maintenance and upgrade of highway infrastructure.
Critics complain that the focus on highways fails to look at freight as a multimodal system. DOT officials have said they will try to take a multimodal approach within the limits of the law.
In comments filed with the DOT regarding the Primary Freight Network
, IANA asked for the draft map to be amended to include all freight intermodal connectors because they handle large volumes of trucks, maximize the use of each transportation mode and account for less than 1 percent of total National Highway System (NHS) mileage.
"These connectors are critical to the mobility of freight movements and are the actual ingress and egress between intermodal facilities and the NHS. Without them, the PFN paints an incomplete and inaccurate picture of international and domestic freight shipments," it said.
The designation is all the more important, the trade group said, because intermodal connectors are "underfunded when compared to the rest of the National Highway System and the cost of backlog improvements is over $2.5 billion."
IANA, which represents many motor carriers, railroads, ocean carriers, port authorities and logistics companies, said the Federal Highway Administration's use of annual average daily truck traffic is not always the best metric for capturing which segments of the NHS should appear on the Primary Freight Network and urged it to engage industry groups that may have additional data that could benefit the analysis.
IANA also suggested that private infrastructure such as seaports and inland intermodal terminals may be appropriate to include for purposes of defining the Primary Freight Network because of their importance to national goods movement.
The association also endorsed the FHWA's approach of designating freight corridors rather than specific highways because it will allow for redundant routes that can bypass recurring congestion and optimize freight flows.
"While the PFN requires a great deal of improvement to accurately represent goods movement, IANA commends Congress and FHWA for beginning the process of elevating freight's profile through coordinated policy and planning," IANA President and Chief Executive Officer Joni Casey, said in a statement.
The DOT requested comments on specific route modifications to the draft primary highway designations, the methodology for choosing the routes, how the national freight network may fit into a multimodal national freight system and suggestions for an urban-area route designation.