Criteria for Funding BRAC Transportation Improvements
Update: DOD responded positively to this comment in the final criteria issued Sept. 9. Rather than adding three new criteria as we requested, the three items we proposed were included explicitly as part of criterion (d).
Comment to U.S. Dept. of Defense, August 19, 2011
Submitted by ACT Pedestrian and Bicycle Committee Chair Richard Hoye
I am submitting the following comments regarding the Announcement of Federal Funding Opportunity, FR Doc. 2011–18400 Filed 7–20–11, on behalf of the Action Committee for Transit, PO Box 7074, Silver Spring, MD 20907-7074. I request confirmation of your receipt of these comments.
The Action Committee for Transit believes that the selection criteria (Part V. Application Review Information, Item 1. Selection Criteria, parts "a" through "d", Page 43666 FR/Vol. 76, No. 140, 7-21-11) for the Notice of Federal Funding Opportunity are too narrowly drawn.
(1) The criteria do not address the potential for negative impacts of transportation projects on DoD facilities, service personnel and support employees.
On base parking facilities are costly while they also obstruct and impede the location and operation of productive buildings and operations. Structured parking also introduces the potential for crime, suicides (as has happened at the NNMC) and delayed evacuation of the base having such parking in the event of natural disaster or terrorist event.
Off base transportation projects that rely on increased automobile capacity by more and wider traffic lanes and other means negatively impact access to DoD facilities by bicycle, transit and walking. Criteria should recognize and weigh this issue based upon the context-for instance, a DoD base in an urban setting with greater potential for reliance on non-auto means of transportation should be more critically evaluated.
(2) The security of DoD service personnel and support employees/contractors accessing and leaving DoD facilities by means of the projects reviewed for funding is not addressed.
Does the transportation enhancement project under review mitigate a target hazard associated with the DoD facility? [Discussion of specific vulnerabilities redacted.]
Does the transportation project create hazards or risks needing constant attention?
Based on the concerns above, ACT requests that at least three additional criteria be added to Section V, Part 1 of the Announcement of Federal Funding Opportunity:
e) The extent to which the project contributes to on base parking demand (negative factor) or relieves parking demand (positive factor).
f) The impact on pedestrian, bicycle and transit access to to the DoD facility of the project.
g) The degree of mitigation (positive factor) or contribution to vulnerability of terrorist attack or major accident (negative factor) of an existing or proposed transportation facility.
I thank you in advance for considering Action Committee for Transit's comments.