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The Sierra Club Opposes New TRAC Scoring Revisions
May 20th, 2011
The Ohio Department of Transportation wants to change the language and criteria for assessing TRAC (Transportation Review Advisory Council) projects. The proposed changes will further limit the likelihood that projects that expand transportation choice and reduce congestion and emissions will be funded.
We want ODOT to move Ohio’s transportation forward; these proposed changes do just the opposite.
See our submitted comments below:
May 20, 2011
Ohio Transportation Review Advisory Council
Ohio Department of Transportation
Attn: Ed Kagel, PE
1980 West Broad Street
Columbus, Ohio 43223
Dear Director Wray and TRAC Committee Members:
The Sierra Club appreciates the opportunity to comment on the Ohio Department of Transportation’s (ODOT) proposed scoring revisions for TRAC projects, but we do not support these revisions. We oppose the revisions for number of reasons, as will be outlined below. But fundamentally, we oppose the revisions because they would reduce the importance of the multi-modal characteristics of proposed transportation projects, making these types of projects less likely to receive funding. In light of Ohio’s congestion rate, which has been increasing consistently over the last thirty years, and continuing increases in vehicle-miles traveled (VMT), the multi-modal aspects of transportation projects should be given more, not less, weight in TRAC assessments.
The most cost-effective way to address congestion and high VMT in Ohio is to provide feasible alternatives to automobile travel. The proposed changes to TRAC project scoring limit the likelihood that projects designed to expand transportation choice will be funded. The TRAC document states that ODOT’s policy is to consider all modes equally. However, we believe projects that expand the utilization of non-automobile modes, decreasing fossil fuel reliance, reducing congestion and VMT, and potentially stimulating more economic activity than automobile focused projects, should be prioritized over projects that simply expand Ohio’s road network and perpetuate the transportation status quo. It is also important that ODOT plan not just for the present but the future, and in doing so, it must recognize that our present transportation system is constructed on an unsustainable edifice of fossil fuel use.
It is also troubling the document lacks any specific mention or discussion of passenger rail. Ohio’s population distribution and geographic location make it highly suitable for corridor passenger rail service. The Sierra Club would like to see ODOT make passenger rail a higher priority. Inter and intra-city passenger rail systems have been shown to encourage economic development, reduce congestion and VMT, and provide individuals with more transportation choice. Rail has also been shown to have positive impacts on public health by reducing traffic fatalities and improving personal health. Many times, rail projects have a larger impact on economic development than comparable road projects. The congestion mitigation and economic growth benefits from road spending have been steadily diminishing in recent decades – it is important ODOT recognize this.
It is encouraging that ODOT mentions and recognizes the importance of “fixing-it first.” In Ohio, 23 percent of bridges, 20 percent of interstates, and 44 percent of other roads are in need of repair. Addressing these distressed roads and bridges certainly offers ODOT a great opportunity to make Ohio’s roads safer and create jobs while limiting the negative health and environmental consequences from constructing new lanes and roads. The Sierra Club also urges ODOT, whenever possible, to address the needs of not just motorists, but bicyclists and pedestrians by providing proper accommodations to these two groups when repairing and building roads.
Prioritizing projects to locations where communities can contribute larger percentages to project costs disadvantages lower income communities that have fewer resources to contribute. Although ODOT does allocate up to five TRAC scoring points for factors related to economic distress, this does not counteract the greater number of points allocated for project sponsor investment factors. It is also disappointing that emission reductions factor minimally into project scoring; as it stands, they account for only five percent of the scoring weight for project evaluations. Emission reductions should receive more emphasis in TRAC scoring, as it is critical that we curb vehicle emissions in Ohio to protect human health and the environment.
The Sierra Club hopes ODOT will engage in a critical appraisal of the proposed TRAC scoring revisions, based on submitted public comments, and adjust its scoring criteria to better account for factors such as congestion and VMT reductions, emissions abatement, and transportation choice. We believe that a significant opportunity exists to improve Ohio’s economy, environment, and its citizen’s health through transportation reform, and we remain hopeful that ODOT will take full advantage of it.
Conservation Program Coordinator
Sierra Club Ohio Chapter
614-461-0734 ext. 316
131 N. High St.
Columbus, Ohio 43215