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TEXT OF A LETTER TO SECRETARY OF TRANSPORTATION FEDERICO PENA REGARDING THE DOT RESTRUCTURING PROPOSAL
This is the text of a letter our Institute sent to Secretary Pena with comments on the proposed DOT restructuring before the agency released a more detailed proposal on Feb. 2nd. The issues expressed in the letter are still germane to the proposal.
January 19, 1995
Honorable Federico Pena, Secretary
U.S. Department of Transportation
400 7th Street, S.W.
Washington, D.C.
Dear Secretary Pena: Thank you for affording me and many others the opportunity to offer suggestions as you and Department of Transportation staff put together the final package of recommendations for reorganizing the department. As I discussed your preliminary proposals with my colleagues within the University and in the infrastructure industry, it became apparent that, in order to react to so significant a restructuring of the federal transportation functions and programs, one needed to base any suggestions on a conception of the appropriate role of the federal government in the provision of the nation's transportation system. While my thoughts touch on intermodal aspects of air and water transportation, given my perspective as a former big-city transportation engineer, public works official, budget director and elected chief executive, they are understandably mainly focused on surface transport. The compelling national interest in certain aspects of the development and operation of the U.S. transportation system manifests itself in five areas:
- With the ever-growing importance of continually improving the economic productivity of the U.S. economy in the face of rapidly-accelerating global competition, there is a national interest in the provision of a transportation system which allows for economically effective movement of people, raw materials, finished products, energy, and information within, into, and out of the United States.
Given that the costs of transportation are an unproductive burden on families and businesses, there is a national interest in providing that transportation system at the lowest possible cost.
Since transportation is a major consumer of land, energy, and other natural resources, and a major contributor of environmental pollution, there is a national interest in providing a transportation system with a minimal detrimental environmental and resource impact.
Because of its critical importance to the quality of life and standard of living of all Americans, there is a national interest in providing a transportation system with maximum accessibility -- some would say universal accessibility -- for the nation's people regardless of age, race, income, or physical disability.
- In spite of the country's current dominant military posture in the world, there is a national interest in providing a transportation system which can solidly support the nation's defense, and one which is independent of foreign interests for its continued operation.
Given the sweeping nature of the proposed reorganization, it is obvious that the department is determined to recommend a significant reduction in the number of programs and the number of administrative agencies within the department. Assuming that this "downsizing" is a given, I can express no preference between the air-land-sea and the infrastructure-safety-Coast Guard organization structures. It goes without saying that each would require exceptional management efforts to achieve the necessarily significant cross-functional consolidations and coordination within the new administrations.
Likewise, I cannot suggest any major alternatives to the three-program block grant, infrastructure bank, regional/national significance project categorical grant arrangement. Rather, my five suggestions focus on policy and program recommendations within the general context of your proposed organizational and program restructuring:
- The only way that the department -- and by extension the federal government -- can ensure that the national interests of economically effective movement and minimal cost are achieved is by requiring that states and urban areas prepare, maintain, and adhere to technically rigorous transportation system plans, and that federal funds are only available for projects drawn from such plans. This is not to suggest that the federal government should prescribe in detail what such plans should contain. Rather, the role of the federal government should be to build on the planning requirements of the last forty years to require that states, counties, municipalities, transit operators, private transportation entities, concerned transportation consumers and citizens continue to cooperatively develop robust, locally-responsive, and realistic plans for their transportation future. If the department had no role in surface transportation other than to require such planning, it would probably be enough to guarantee a reasonably positive outcome.
To ensure that the national interests of economically-effective movement and national defense are protected, the department needs to work with the states and localities to provide for a system of nationally and regionally significant interstate transportation facilities and services. This National Transportation System should contain, at minimum, intercity passenger and freight components, and should focus on regional and national coordination within and between modes. I realize you and the department were in the middle of defining an NTS when the restructuring imperative occurred, but I would strongly urge you to keep this as an important element of your proposal. This effort should also address consistent standards for such seemingly-mundane but nevertheless critically-important matters as minimum bridge clearances, structural capacities, geometrics, signage and lighting standards, and safety issues, among others.
As one who has a great deal of trouble with the travel behavior modification provisions of the Clean Air Act Amendments, I nevertheless believe that the state and regional transportation system plans must be required to contribute in an identifiable and quantifiable manner to the achievement of national environmental and resource objectives. I know the Congress is likely to revisit this matter in great length in the near future, but again I would urge the department to address this clear national interest in your restructuring proposal.
It is in achieving environmental, resource, and accessibility areas of the national interest that your proposal's approach to urban transit must be positioned. If transit is simply thrown into a competition for block-grant funds with roads without some protection, the likelihood is that transit will die in many urban areas and shrink substantially in almost all the others. Like it or not, thirty years of dependency on federal formula and line-item largess has made it unlikely that transit can effectively either compete with highways for funds that you would be the first to admit are insufficient to meet the needs of both, or successfully "flash cut" transition to the private sector. Either some sort of set-aside or other protection, or a fairly lengthy sheltered transition period is needed to protect transit. If you leave transit the fend for itself, it cannot survive, and those who depend on it will be grievously impacted. Also, your proposal hints that cities will receive direct fund allocations and not be subject to the whims of the state governments. I sincerely hope you follow through on this. The Intermodal Surface Transportation Efficiency Act puts cities at some disadvantage with regard to states, and to achieve the national accessibility interest, the state-city power imbalance needs to be redressed.
- Finally, as we at the Institute look at the need for better infrastructure technology, it has become clear that only the federal government possesses the critical mass of strength and resources to effectively promote the development and deployment of innovative technologies. Therefore, I would strongly urge you to reinforce the department's historic record of achievement in the transportation technology arena. This is also important in keeping the U.S. transportation system from becoming overly dependent on foreign technology, with both the national security and economic impacts which that would have.
In summary, I would suggest that there is a strong national interest in a transportation system which provides economical movement at the lowest possible cost while minimizing detrimental environmental and resource impacts, conferring maximum accessibility to all citizens, and supporting the national defense. While not suggesting any significant changes to the proposed administrative or programmatic structure, I do recommend that the restructuring provide for: (1) state and regional transportation plans, (2) a National Transportation System of coordinated interstate and intermodal facilities and services, (3) requiring plans to contribute to achieving national environmental and resource policy goals, (4) protection of cities and public transit, and (5) a strong continued federal role in the development and deployment of innovative transport technology. Thanks again for the opportunity to contribute to your important deliberations. If I can be of any further assistance, please do not hesitate to contact me.
Sincerely,
David F. Schulz
ITI Executive Director
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