January 30, 2007

Mr. Terry Kraft, AICP, P.E.
Senior Transportation Planner
Florida Department of Transportation
Office of Policy Planning
605 Suwannee Street, MS 28
Tallahassee, Florida 32399-0450

RE: Comments on Implementation of Florida's Future Corridors Action Plan

Dear Terry:

Thank you for the opportunity to provide comments on the implementation of Florida's Future Corridors Action Plan. While we have many comments on individual portions of the various implementation sections, we would like to focus on the overarching concept of regional visioning.

As we have previously stated in our earlier letters of October 16, 2006, and November 27, 2006, we strongly believe that the designation of a future corridor or the reuse of an existing one should be done in context of an overall vision of land use, conservation and transportation for the region. (Please consider the attached earlier correspondence as part of these comments.) Without these visions, we are simply putting a new name on the old processes that have lead us to our current state of backlogs, conflicts, and unsustainable land use patterns. Our future transportation decisions need to be planned and implemented in concert with land use and conservation, as one integrated system.

After reviewing the implementation document, it is extremely troubling to see that FDOT is already moving forward to implement four prototype future corridor studies over the upcoming year. Table 4 on page 23of the Action Plan describes the individual prototypes and identifies the objectives of the four studies. Only one prototype corridor's objective references the concept of planning within a regional context. The other objectives seem to strive to implement the status quo (congestion relief, connectivity, freight mobility) in isolation of supporting a greater vision. This is very disturbing.

Additionally, these prototype studies will begin with the establishment of a Corridor Action Team for each study area. Based on the description of the three stages of the Future Corridors Action Plan, this means that these studies will begin at the Feasibility stage. This implies that the analysis done to date to identify and justify the proposed new corridors and reuse corridors as identified in the "Inventory/Status of Study Areas & Corridors, Explanation of Re-Use Corridor Analysis" is enough to satisfy the goal of the Concept stage. If that is in fact the case, any corridor project could be drawn on a map and, with very little effort, meet this standard of justification. The data and application of criteria currently described on the individual project pages is superficial and generic. As we have previously suggested, the primary outcome of the Concept study stage should be a vision for the corridor and/or region that includes a 50 year plan for land use, conservation and transportation. No prototype study should move forward without such a vision in place and a clear indication that the proposed corridor or corridor reuse is consistent with that vision.

The criteria for review within the Feasibility and ETDM/PD&E also do not seem to move beyond the implementation of existing processes. Regional visions are not a requirement. The detailed screening criteria heavily emphasize improved travel time, filling a "system gap", increased freight traffic, potential job creation, etc. These are the criteria which traditionally have been used to identify the need for capacity improvements. The descriptions associated with the Community Livability criteria and the Environmental Stewardship criteria, in contrast, focus on things that "may indicate" areas to avoid or mitigate. Based on this description of the detailed screening criteria, we are not going to reach any different outcomes than we do in the existing processes. The proposed corridor does not have to be consistent with a comprehensive vision for the future; rather, the vision can continue to be created by default, just as it is today. Corridors could be justified solely on mobility and connectiveness criteria, with community and environmental factors simply tweaking the location of the corridor, not influencing the overall justification or rationale for the corridor. As so clearly stated on page four of the section dealing with linking corridor planning to economic development and land use, major transportation corridors generate additional growth. It is extremely important that this growth be consistent with the vision of where the region and its communities, not driving that vision.

We urge FDOT to delay the initiation of any new corridor or reuse studies until changes to the process can be made to insure that a regional vision exists to guide those decisions, and review criteria provide true consideration of community, environmental and transportation issues as an integrated system. Given that the goal of this Action Plan is to proactively plan for 50 years in the future, taking the next two years to get the regional visioning process underway would only be prudent. It seems counterproductive to leap into implementing four corridor projects when the core concept of this new program, planning future transportation, land use, and environmental stewardship in an integrated manner, does not exist.

Thank you again for the opportunity to provide comments. We look forward to discussing our concerns with you and working towards a resolution.

Sincerely,

 

Tim Jackson, P.E., AICP, Vice President
Charles Pattison, AICP, Executive Director

Attachments: Letter of October 16, 2006
Letter of November 27, 2006

Cc: Lester Abberger, 1000 Friends of Florida
J. Allison DeFoor, 1000 Friends of Florida
Charles Lee, Audubon of Florida
Charles Draper, Audubon of Florida
Steve Seibert, The Seibert Law Firm
Lennon Moore, Orlando Orange County Expressway Authority
Charlie Gauthier, Florida Department of Community Affairs
Diana Sawaya Crane, Office of the Governor
Florida Regional Councils Association
Marcos Marchena, Florida Transportation Commission
Manley Fuller, Florida Wildlife Federation
Andrew McElwaine, Conservancy of Southwest Florida