Dear Mr. Comer:

                This letter contains the response by RAIL Solution to the Task 4 Technical Memorandum entitled, “Project Priorities – A Corridor Plan”. It is being sent via first class U.S. Mail postmarked today to meet the requirements of the 30-day comment period. An advance copy is also being sent via e-mail today to Ralph.Comer@state.tn.us pursuant to instructions for comment.

                The Task 4 Technical Memorandum contains the recommendations from a larger, longer-term process known as the “I-40/I-81 Corridor Feasibility Study.” The acknowledged purpose of this planning effort has been to identify capacity deficiencies in the Corridor and to “develop corridor-level, multi-modal solutions to address those deficiencies.”

                RAIL Solution is both amazed and chagrined that the recommendations finally issuing from this long-term planning process embrace $4.24 billion of highway improvements and virtually nothing for rail. This is hardly a multi-modal approach!

                Without a doubt some highway capacity expansion may be needed, and the list detailed in Section 5.3.1 of the Memorandum may well represent a reasoned prioritization of needs. However, to expect this, and the other highway construction shown in Table 5-1, to have any meaningful, long-term impact on trans-Tennessee freight flows, is seriously misguided.

                On the next page are maps from FHWA showing current trucking volume across Tennessee in 2002 and again in 2035. Virtually nowhere in the United States is the volume greater than across Tennessee. Huge flows come together at Little Rock from Interstates 30 and 40, enter TN at Memphis, remain intact across TN, and continue largely so into and through Virginia as well via I-81.

                Clearly it will be an ongoing challenge over many years for TDOT to plan for and accommodate such large truck flows. There are two main coping strategies available to TDOT. One, which is largely the one opted for in the Memorandum’s recommendations, is to continue to rely on making incremental capacity additions to I-40. The second is to embrace a meaningful railroad alternative for handling much of the freight, keeping it off the public highways of Tennessee altogether.

                Any effective planning process has to start with a vision. What do we want freight transportation in the Corridor to be like 30 years from now? A total highway approach such as recommended in the Memorandum, will result in I-40 being under construction almost continually from now on, at enormous economic and environmental cost to the state of Tennessee. If FHWA’s projection is anything near accurate, a constant struggle will ensue to add lanes fast enough to keep traffic fluid in years ahead.

In the end this strategy will fail. We know this based on experiences in other states on the West Coast and in the Northeast where such an approach has been tried. Continual expansion can result in accommodating more trucks, but they will not move through the system any better, pollution and congestion will not be mitigated, and the often near-gridlock conditions will continually and adversely affect automobile drivers.

Ultimately Tennessee will face an outcry from a public that finds the congestion, construction, environmental degradation, and deterioration of quality of life unacceptable. Then, once billions of dollars already have been spent, the state will face a massive regrouping process looking for a different approach, likely focusing on a rail alternative.

The message here is obvious. Start work now on the rail alternative! Don’t wait 30 years or spend $30 billion on I-40 first. For half that amount, in half that time, Tennessee could have a super railroad “steel interstate” in place from Memphis to Bristol that would be capable of moving through trucks on trains for the rest of the 21st Century.

Furthermore, such a system could readily be electrified, substituting domestically generated electricity for dependency on imported oil and assuring continuity in movement of goods and people once oil becomes prohibitively expensive and non-available. No amount of incremental highway capacity will do any good once cheap, abundant petroleum resources, on which our transportation sector now completely depends, are gone.

                The public is more ready than ever before to accept rail alternatives. Railroads are more energy efficient, safer, less polluting (including CO2 and greenhouse gas emissions), and have a far more limited footprint on the land. Tennessee needs to embrace this vision. Tell the story. Set the goals. The vision needs to generate excitement and buy-in, which in turn generates funding. The current gas crisis, accompanied by growing concerns over global warming, have made the public more demanding than ever before of non-highway solutions. Vehicle miles traveled have dropped sharply on a year over year basis. As a state, and as a nation, we need to refocus from adding ever more lanes of highway, as during the Eisenhower Interstate Era, to maintaining what we have and redeploying our infrastructure capital investments to rail.

                In reviewing the I-40/I81 Corridor Feasibility Study and the Task 4 recommendations, we find such a vision totally lacking. There are several reasons that may help explain why.

                First, where rail alternatives are considered, they are tentative and inadequate. This repeats a fallacy we have become only too familiar with during five flawed studies conducted previously in Virginia. Minimalist rail options are evaluated alongside major, multi-billion dollar highway options, the rail options show up poorly, and they wind up being denigrated and discarded. Rail options need to be on a similarly bold scale as highway proposals. Only then can substantial highway construction be avoided and savings credited to the rail project side of the ledger, helping public benefits significantly exceed public costs. Only then can adding new capacity on highway vs. rail be reasonably compared both economically and environmentally.

                Second, Task 4 mentions favorably in several places Norfolk Southern’s Crescent Corridor initiative. There is nothing wrong with the NS plan, and TN may indeed want to support its proposed share. But don’t expect it to have any significant, long-term effect on diverting trucks from the I-40 Corridor. The NS concept is focused almost entirely on moving shipping containers. While it is true that such containers might add to I-40’s future woes if hauled by truck instead of NS, there is nothing in the Crescent Corridor plan to remove through trucks from I-40, either now or in the future. Don’t think, “Well, NS is going to take care of things so we don’t need to worry about the rail side.” What NS is up to may help. But it is no substitute for a true open-intermodal super railroad bridging through trucks across Tennessee.

To be meaningfully comparable to proposed highway capacity additions, rail alternatives need to be truck competitive in speed, reliability, and cost. Today’s rail infrastructure is wholly inadequate in Tennessee, and in many other places, to do that. Highway expansion needs to be evaluated against a high-capacity, multi-track, signaled, grade-separated, and ultimately electrified rail corridor that we refer to as the steel interstate. Because of the large and consolidated freight flow across the state, Tennessee is in an unusually favorable situation to pioneer this promising 21st Century concept.

RAIL Solution is a grassroots rail advocacy group with approximately 1200 participants concentrated mostly in the I-81 Corridor of Virginia and northeast Tennessee. Much of what we have worked for over the past six years in Virginia is equally applicable to what Tennessee is wrestling with in the I-40/I-81 Corridor.

                A RAIL Solution brochure is enclosed. Additional information is available on our website www.railsolution.org

Thank you for the opportunity to share our views and participate in this vital transportation planning process. We would be pleased to be able to continue involvement and participation in the I-40/I-81 Corridor of Tennessee.