David Streb - Comments

Federal Railroad Administration, Docket No. FRA-2012-0066 Concerning Request for Public Comment on Proposed State Rail Plan Guidance: The Oklahoma Department of Transportation would like to share the following input. The new guidance issued by the Federal Railroad Administration related to creation of a State Rail Plan seeks numerous data and planning inputs and categories (such as “land use planning”) that may be delivered or conducted in various formats or methodologies—there is no “one best answer” to many of the inputs being requested. It is imperative that should the FRA decide to keep all of these requests in their final guidance that they offer the States more thorough information on the methodologies and data inputs they would like States to use for the reporting. Determining a set of standards that can be applied across the country will allow the States to better carry out their missions of working to generate regional and national rail plans, of producing documents that are capable of “speaking” to each other to create a larger product out of the individual parts. We would also like to request that the Guidance reflect the need to include funding possibilities for “short notice” projects or programs that may emerge in between periodic state rail plan updates. Situations arise, such as the TIGER program, that offer States opportunities to fund projects that they may not have accounted for owing to a lack of foreknowledge regarding such emerging funds. We believe there needs to be a mechanism/ additional guidance to define how such situations can be covered. In addition, crises may emerge that require emergency funding, and we would prefer to see some Guidance that formally addresses such situations to assure a broad interpretation of federal funding eligibility for rail projects.