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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � 6 Information and Analysis for Decisions The central task of this study is to develop an analytic framework for federal policy makers to use in identifying key needs of the nation’s marine transportation system (MTS) and in targeting efforts to meet them. To develop such a framework, the federal sponsors of this study asked the committee to Review how federal agency investments in the MTS are now made, including the degree of interagency coordination of investment decisions and the policy issues associated with patterns of investment; Review and interpret projections for future maritime demand;

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Assess plans for MTS maintenance and expansion by industry, state and local governments, and federal agencies; Describe the likely impact on the MTS over the next two decades if federal funding remains constant; and Identify options for federal funding of the MTS, including analyses of the federal financial role in other transportation modes and the factors and trade-offs that must be examined when alternative federal financing roles are considered. For reasons given in Chapter 1, the committee chose to address these tasks by Examining 20-year forecasts of marine transportation demand; Reviewing the federal programs related to the MTS and the interests these programs are intended to serve; Examining available government and industry reports on the performance, condition, and needs of the system; and Comparing the federal roles and responsibilities related to the MTS with those of other major modes of transportation. The study results are presented in Chapters 2 through 5. In the committee’s judgment the results suggest that a more systematic and analytical approach to federal decision making is warranted. Such an approach would make more efficient use of federal resources and ensure that federal decisions are compatible with furthering national interests and capable of meeting the growing demands placed on the MTS. In particular, the results indicate the following: Anticipated growth in production and trade over the next several decades will cause the MTS to become even more heavily used and critical to the functioning of the national economy. Even today, the

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � performance of the MTS affects the operations, structure, and efficiency of many other transportation modes and industries throughout the economy. The system, which is a public- and private-sector enterprise, is becoming increasingly enmeshed in the nation’s surface transportation system to form a vast multimodal freight system. As pressures for such integration intensify, they will almost certainly be accompanied by changes in federal, state, local, and private-sector responsibilities, investments, and services. Federal involvement in the MTS stems from a commitment to ensuring marine safety, protecting the marine environment, facilitating commerce, and providing for national security. Not only are these important national interests, they are fundamental responsibilities of the federal government rooted in the U.S. Constitution. Yet, the responsibilities are carried out through many different and often unconnected laws, policies, programs, and agencies—some having origins that extend back to the nation’s founding. As a result, federal involvement in the MTS is dispersed among more than a dozen agencies and cabinet-level departments, which has made it difficult to understand and coordinate the federal influence on the system and to gauge progress in furthering national interests. In general, the division of federal responsibilities does not correspond well with how the MTS is structured and functions today. There is a pressing need for well-informed and well-coordinated federal decision making with regard to the MTS. As the MTS has become more heavily used and integrated into the economy, demands have grown for it to perform more safely and securely and with fewer adverse environmental effects. The challenge before all parties with responsibility for the MTS, including the federal government, is to elevate system performance in all these dimensions and to simultaneously meet the demands of commerce. Because so many federal decisions affect MTS performance, it is essential to make them with an understanding of their effectiveness, consistency with one another, and broader implications.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Decision makers in the federal aviation, highway, and transit programs depend on objective and national-level information on system conditions, use, and performance. The development of this information has helped assure users that federal programs are aimed at bettering the systems. Users of these transportation systems have come to accept broad-based user charges and national trust funds as means of financing the federal transportation programs. By themselves, good system performance data and analyses cannot ensure more consistent and effective public choices. Information must be accompanied by the political and institutional structures, incentives, and capabilities to use it. To a great extent, the federal aviation and highway programs are administered by single agencies under the jurisdiction of a handful of congressional committees, which have required the agencies to gather and report system performance and condition information on a regular basis. In fact, Congress has repeatedly sought improvements in data quality, coverage, analysis, and policy relevance. It puts this information to use as it authorizes spending from the national trust funds to improve transportation system capabilities and performance. The beginnings of an analytic framework are offered in this chapter. Within that framework, decision makers can view the components of the MTS, their uses, and federal programs in a more systematic and comprehensive manner and with more explicit consideration of the national interests that underlie federal involvement. The framework is intended to facilitate, and even compel, the identification of federal priorities on the basis of multiple interests and perspectives, including many that are hard to recognize from the narrower vantage points of individual agencies, users, and system components. Implementing such a framework will require good data on system use, performance, conditions, and needs. The framework itself will provide a structure, or template, for organizing this information in ways that will better support the making of investment decisions and the setting of performance goals by federal policy makers. The federal agencies now involved in the MTS already gather and analyze much information, but

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � on specific aspects of the system. The fragmentation of federal programs and decisions related to the MTS has led to a fragmentation of information. National-level, crosscutting information on system performance and impacts is unavailable or limited. The chapter concludes with recommendations for the gathering and analyzing of information on MTS performance, condition, and needs in a more concerted manner. Recommendations are also made with regard to other actions that should be taken to address particular concerns identified in this report. A FRAMEWORK TO SUPPORT DECISION MAKING The development of an analytic framework and the information to support sound decision making is a focus of this report. Federal roles and responsibilities related to the MTS are dispersed, which makes it difficult for federal decision makers to know how their own policies and programs relate to one another and to the concerns of shippers and carriers, providers of MTS infrastructure and services, and the public. An issue appearing to be minor in one context may be viewed as crucial in another. For example, the federal agencies and congressional committees responsible for ensuring adequate waterway capacity may have little direct interest in ensuring that the ports on the waterways have sufficient highway and rail connections. However, shippers may view such connections as integral. Similarly, while federal attention may be directed at regulating vessel design as a way to ensure marine safety, vessel operators may view improved hydrographic data and the training and retention of qualified crew as having comparable importance. Recognition of these different perspectives is important in ensuring that federal decisions are consistent and aimed at furthering priorities. In particular, four national interests are referred to repeatedly in this report in discussing the federal role in the MTS: Ensuring marine safety, Protecting the marine environment,

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Facilitating the nation’s commerce, and Promoting national security. In the committee’s view, furthering and balancing these interests are central to federal involvement in the MTS, but individual federal agencies may not view their own roles and contributions in direct relation to them. Decisions are often aimed at meeting specific statutory, program, and budgetary commitments, which may not align well with national interests. More generally, the federal government itself has chosen to focus attention on certain components of the MTS while leaving others to state, local, and private entities. Accordingly, when federal policy makers seek to enhance MTS performance with regard to these national interests, they are inclined to focus first on highly visible system components that are most directly within the federal domain. Opportunities to advance national interests from outside this traditional domain may be neglected. Four major components of the MTS warrant consideration when federal involvement is examined: Harbors and seaways, Inland and intracoastal waterways, Ports and terminals, and Intermodal connections. Each of these components is important to MTS performance with regard to the four national interests listed above. However, the federal domain consists primarily of the first two components, which comprise the navigation and waterside elements of the MTS. A simple matrix, as shown in Figure 6-1, provides a framework to begin thinking more systematically and broadly about federal opportunities for furthering national interests. Each interest and MTS component presents its own challenges and concerns. Even a cursory listing offers a starting point for assessing federal priorities.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Figure 6-1 Matrix for assessing the relationship between MTS components and national interests. Additional dimensions can be added to the matrix for a more comprehensive decision-making framework. For example, the perspectives of MTS users such as the passenger, dry bulk, liquid bulk, and container segments (Figure 6-2) and federal agency roles (Figure 6-3) can be added. This framework can be used to Identify needs from the multiple perspectives of federal agencies, users, operators, and infrastructure providers; Assess current efforts to address needs across institutional and public-and private-sector domains; Identify gaps in responsibility for addressing needs or in coordinating actions to address them; and Assess options for meeting needs and improving performance. Such a framework should compel consideration of the federal influence on the MTS in a more systematic fashion that recognizes the interrelationships among national interests, the components and users of the system, and the roles and responsibilities of federal agencies. This process will raise many questions about the scope and scale of federal involvement

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Figure 6-2 Matrix for assessing the relationship between MTS components, national interests, and user segments. in the MTS and the performance of federal agencies. Among the questions are the following: What are the safety and environmental challenges associated with liquid bulk transportation, where are the challenges the greatest, and how are the federal agencies, individually and collectively, performing in meeting these challenges? Which federal agencies have responsibility for ensuring that the MTS meets the needs of national security, and for which system components

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Figure 6-3 Matrix for assessing the relationship between MTS components, national interests, and federal agency roles (MARAD Maritime Administration; NOAA National Oceanic and Atmospheric Administration; USCG = U.S. Coast Guard; USACE U.S. Army Corps of Engineers). is each agency responsible? Are there security issues associated with specific uses of the MTS, and are they being adequately addressed? Are crosscutting security concerns being recognized as such by the multiple federal, state, local, and private entities with security roles and responsibilities? Where are the constraints on MTS capacity to accommodate commerce, and what is the federal role in addressing them? How does this

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � role relate to the federal role in providing capacity-enhancing infrastructure and services in other parts of the system, such as connections from the waterways to other modes of transportation? Many of the questions raised will undoubtedly require more information and analyses to answer. One of the advantages of such a framework is that it can be used to identify data and analysis capabilities that are needed to support policy making. During the course of this study, the committee interviewed users of the MTS and reviewed reports identifying critical system shortcomings and needs. A number of concerns were raised repeatedly. When these concerns are examined from the perspective of the above framework, it is evident that many fall outside or transcend the jurisdictions of individual federal agencies. Often they have been allowed to persist because they require the attention of more than one federal agency, are emerging and not well defined or understood, or arise in part from efforts to address other concerns. All are candidates for the kinds of performance measuring and monitoring urged in this report. Some, in the committee’s opinion, deserve early attention because they have the potential to be exacerbated by escalating transportation demand. They include the following: The capability of highways and other intermodal facilities at major ports to handle increasing container traffic. The challenges involved in integrating the nation’s freight transportation systems, and the jurisdictional issues that arise, are perhaps most apparent at the interconnections of the nation’s public seaports, public highway systems, and private railroads. At these points, federal, state, local, and private-sector interests and responsibilities intersect, but they are especially difficult to coordinate because of differing planning horizons, resource constraints, and investment priorities. The ability of the federal government to respond effectively to changing vessel traffic, sizes, and uses in the provision of navigation infrastructure. As it seeks to provide harbor channels, locks,

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � and other navigation infrastructure, the federal government faces multiple and sometimes conflicting demands. Most notably, demands for the increased use and capacity of the nation’s waterway infrastructure often conflict with demands for environmental protection. Absence of systematic and comprehensive efforts to strengthen marine safety, security, and environmental protection. The fragmented roles of the federal agencies in promoting marine safety, security, and environmental protection have led to many prevention, mitigation, and response activities, each tending to focus on specific subsets of problems. The result is a mix of efforts, such as economic protections afforded domestic shipbuilders and carriers in the name of promoting national security and the regulation of vessel designs and operations to promote safety and protect the marine environment. Other options to help achieve these goals may be considered, such as improving infrastructure and navigation information, but seldom in a systematic way. An examination of safety, security, and environmental needs will be important in ensuring that the nation’s commerce is unhindered and that pressures from increased commerce do not compromise such needs. To address these concerns, policy makers will need good information on the condition, performance, and utility of the MTS. They will need more objective measures of how well the various components of the MTS are performing with respect to safety, the environment, commerce, and intermodal access. They will need to know how resources are committed by the various federal programs and how the resources correspond to performance expectations and results. However, performance-related information on the MTS is limited, as discussed in the preceding chapter. The information that is collected is designed and used mostly for assessing the performance of individual parts of the system and is seldom related to overall system performance. Actions aimed at making the gathering, analysis, and use of such performance information a requisite part of federal policy making are recommended in the next section.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � RECOMMENDATIONS U.S. Department of Transportation to Monitor, Advise, and Regularly Report on MTS Conditions and Performance Each of the four broad areas of national interest that underlie the federal role in the MTS is being pursued to varying degrees by several federal agencies and programs. In some cases, a single federal organization has a clear leadership role (e.g., the Coast Guard for marine safety), while in other cases leadership responsibility is not well defined. No single entity is responsible for examining how the many federal activities and decisions related to the MTS affect all of the national interests that underlie federal involvement. The transfer of the Coast Guard from the U.S. Department of Transportation (DOT) to the newly created Department of Homeland Security (DHS) in March 2003 has altered federal agency linkages and responsibilities. This transfer—along with that of the Transportation Security Administration, the Bureau of Customs and Border Protection, and other federal agencies—has consolidated and made more prominent the federal role in ensuring the security of the MTS. At the same time, it has revealed the extent to which the Coast Guard served, mostly informally, as coordinator and facilitator of an MTS that is not only safe, secure, and environmentally sound, but that is responsive to the needs of commerce. The agency was transferred to DHS with the understanding that it will continue to meet its long-standing environmental and safety responsibilities. Of course, the Coast Guard is expected to meet its statutory responsibilities; however, it faces a greater challenge in maintaining the facilitator and coordinator roles that it long filled as the largest marine-focused transportation agency within DOT. Not only has the creation of DHS further dispersed federal involvement in the MTS, it threatens to diminish DOT’s role in the marine sector. The Coast Guard’s transfer has left the Maritime Administration (MARAD) as the primary DOT agency with responsibility for carrying out federal programs directed at marine transportation. MARAD’s statutory responsibilities encompass only certain aspects of the MTS. They

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � focus on the training of merchant mariners, the domestic shipbuilding industry, and the maintenance of a merchant marine capability and reserve fleet for military use. The MTS encompasses much more, even within DOT. For instance, the federal highway program, administered under DOT by the Federal Highway Administration (FHWA), is important to intermodal access. Responsibility for ensuring that such institutional and program connections are recognized and strengthened lies in DOT’s Office of the Secretary. In the committee’s view, the policy office of the Secretary of Transportation is the logical place for monitoring and coordinating all federal involvement in the MTS. No other federal agency involved in the MTS has this overarching perspective or charge. DOT can communicate this information to Congress and the Office of Management and Budget, where the connections among federal agency budgets and policies must take place. The committee therefore urges the following: The Secretary of Transportation should seek a mandate from Congress for DOT to take the federal lead in measuring, monitoring, and assessing options to strengthen the MTS’s contribution to the furthering of key national interests, including commerce, environmental protection, safety, and security. While legislative authorization is imperative to sustain such an effort, DOT should assume this leadership role immediately—thereby demonstrating the value to Congress. Acting in this capacity, DOT can be expected to work closely with the responsible federal agencies across cabinet departments in developing measures of system performance with respect to all MTS components and for all dimensions of performance. It should be charged with assessing federal resource requirements to strengthen performance, identifying critical gaps and shortcomings in performance that may benefit from increased federal attention, and evaluating and recommending policy options to meet performance goals. The analytic framework described in this chapter offers a starting point for undertaking such assessments in a systematic manner.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Much can be learned from the experience of other federal transportation programs about how to build a more integrated federal marine program. DOT and its other modal administrations have experience in gathering and analyzing system performance and condition information to assess future needs and estimate federal funding requirements. The Report to Congress on the Status of the Nation’s Highways, Bridges, and Transit: Conditions and Performance (C&P report) produced every 2 years by DOT, FHWA, and the Federal Transit Administration is a particularly good model of the kind of policy-oriented performance analysis and reporting that should be done for the MTS. DOT should immediately begin to develop, and seek a mandate from Congress to produce on a regular basis, reports on the use, condition, performance, and demands of the MTS modeled after the biennial C&P reports developed for the federal highway and transit programs. Not only should these reports portray current conditions and performance, they should also look to the future by assessing the funding levels and investments required to improve system conditions and performance over time. The kinds of data and analyses included in the C&P reports for highway and public transit are described in Chapter 4. These reports include information on patterns and trends in the scale and scope of the system, the age and condition of infrastructure, the extent and types of use, operational performance (e.g., percent of travel under congested conditions), and environmental and safety performance. Furthermore, the reports contain projections of future demand and the results of economic and engineering analyses of probable impacts of alternative investment levels on various dimensions of performance. The C&P reports for the MTS should contain similar system-level information and assessments. In addition, the C&P reports should assess policy options for improving performance. They should be both analytical and prescriptive. The reports should be designed specifically to help Congress formulate MTS-related policy across federal agencies and programs. Analyses should focus on solutions to identified needs; for instance, how the innovative financing techniques

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � used by the federal government for other transportation investments might be used to meet the infrastructure needs of port facilities and to improve intermodal access. A wide range of metrics, data, and analyses will be required to measure and monitor aspects of the MTS. The focus should be on metrics that translate into performance (e.g., trends in safety and transportation costs) as opposed to simple measures of program output (e.g., miles of channel dredged, number of vessels inspected). None can be expected to be comprehensive, and all will be open to interpretation. Information will need to be obtained from many different sources, including federal agencies, state and local authorities, and the private sector. The very act of gathering, synthesizing, and analyzing such information and relating it to performance should prompt more critical thinking about the scope and effect of federal involvement in the MTS. It should provide many insights into system performance trends that are not now apparent from the scattering of information across parts of the system. The idea is to provide credible, objective, and accessible information on a regular basis that will be useful in prioritizing investments and making policy decisions relating to national interests. Once DOT has the responsibility for producing such reports, it will undoubtedly find many deficiencies in the information available. For example, a more concerted approach to measuring and improving marine safety is likely to reveal shortcomings in the information required to understand all the relevant factors. The accident information that is currently collected by the Coast Guard may need to be supplemented by other information, such as near-miss incident reports by mariners. Such information may prove helpful in assessing safety investments by other programs, such as the Corps of Engineers’ dredging and the National Oceanic and Atmospheric Administration’s surveying and charting activities. Whether efforts to measure, monitor, and assess ways to improve MTS performance will improve coordination across federal agencies and programs remains to be seen. In any event, such efforts will provide policy makers with a better understanding of how federal programs, taken together, can help advance national interests. Much can be learned from

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � the federal experience in other transportation modes, particularly with respect to reliance on user financing. Fees on users of the aviation and highway systems have provided predictable sources of revenue for the federal aviation and surface transportation programs. Comprehensive information on system performance has proved essential to retaining user support for this funding approach. The performance information both helps guide federal decision making and demonstrates to users a federal commitment to bettering the system. Reinvest All User and Trust Fund Revenues in the MTS Another important lesson learned from the other federal transportation programs is that revenues generated from system users must be promptly reinvested back into the system. Efforts by the federal government to monitor system performance and identify critical needs will help assure users that federal investment decisions are based on a desire to improve overall system performance. However, these efforts must be accompanied by a commitment to spend the user-generated revenues on performance enhancements. The General Accounting Office (GAO) estimates that total federal expenditures on the MTS averaged $3,900 million per year between 1999 and 2001 (GAO 2002, 3). The construction, operation, and maintenance of navigation infrastructure accounted for about 45 percent of the total federal expenditures, or about $1,750 million per year (GAO 2002, 12). Fees charged to commercial users of inland waterways (about $90 million per year) and harbors (about $750 million per year) cover about half the federal outlay on infrastructure. GAO estimates that about 25 percent of total federal expenditures on the MTS are derived from user fees. Whether more or less user financing of the MTS is warranted was not considered by this committee. Congress has chosen to pay for much of the federal MTS and services through general fund revenues, in part because some of the infrastructure and services have other benefits to the public (e.g., recreation, flood control). However, where user fees have been established for specific federal activities, such as lock improvements

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � and harbor maintenance, the revenues generated have not been reinvested back into the system at the rate promised when the fees were established. The federal highway and aviation programs, which are paid for almost entirely from user fees, demonstrate the potential for user financing to provide a reliable source of funds for system improvements. In both cases, Congress demonstrated its commitment to fully reinvest revenues in the systems—a commitment that has, in turn, led to greater reliance on user fees and increased acceptance by the user communities. The committee is convinced that for user financing to succeed in the MTS, it must be accompanied by a federal commitment to reinvest all of the generated funds back into the system. It therefore urges the following: The administration, supported and informed by DOT and the U.S. Army Corps of Engineers, should seek from Congress the commitment to fully and promptly reinvest all user-generated revenues back into the MTS. The commitment should be accompanied by the kinds of statutory and political devices used in the federal aviation and surface transportation programs to make it binding. Apply to the MTS What Works in Other Federal Transportation Programs As mentioned earlier, a number of concerns were raised repeatedly during the committee’s interviews with MTS users and reviews of reports: Insufficient capacity of highways and other intermodal facilities connecting to the major ports that handle container traffic; Delays in the dredging of harbor channels to accommodate larger vessels and in the modernization of locks and other inland waterway infrastructure; and Absence of systematic and comprehensive efforts to strengthen marine safety, security, and environmental protection.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � Experiences from other federal transportation programs suggest opportunities for addressing these concerns. In the committee’s view, such opportunities should be vigorously pursued to help bring about integration of the nation’s freight transportation systems. The following recommendations are offered in this spirit: The Secretary of Transportation should seek from Congress a more balanced set of tools to make national transportation investment and policy decisions that recognize the increasing integration of the transportation modes and the effects that federal decisions concerning one mode have on other modes. As a first step, DOT should examine and advise Congress on ways to expand the scope and flexibility of existing federal transportation investment and finance programs so that they can be used more effectively for the development of multimodal and intermodal transportation facilities. It is not enough to encourage federal policy makers to take a multimodal perspective on transportation investment and policy making; they must also have sufficient tools at their disposal to act from this perspective. The Secretary of Transportation should seek from Congress the means to undertake, in collaboration with industry and other federal agencies, an applied research and technology program aimed at furthering the capacity, safety, environmental protection, and security of the nation’s ports, intermodal connections, and other marine facilities and services. This effort should include collaboration with the U.S. Army Corps of Engineers to explore opportunities for applying technology, including intelligent transportation systems, to the inland waterway system and with DHS and its agencies to pursue technologies to strengthen system security. Experience from other federal transportation programs suggests the value of federal support of research in improving the national transportation system; thus, a comparable supporting role in the furthering of the national MTS deserves consideration.

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The Marine Transportation System and the Federal Role: Measuring Performance, Targeting Improvement - Special Report 279 � � � � � � As part of its efforts to measure and monitor MTS performance, DOT should aim to develop a more thorough understanding of the operations, capacity, and use of the system, and of the freight system in general. Such an understanding will help identify ways to better integrate security, environmental protection, and safety features and capabilities into the system as it facilitates the nation’s commerce. Examining the implications of federal investments and activities across modes will also be important in ensuring that these investments are compatible with one another and with these national interests. Such outcomes can no longer be treated as mutually exclusive or conflicting goals of national policy, but rather as interdependent and essential to one another. CONCLUDING OBSERVATION The integration of the nation’s transportation modes, particularly for the movement of freight, is a long-term phenomenon that may ultimately compel changes in federal responsibilities and institutions. Short of such change, much can be done to ensure that the federal government remains responsive to the needs of commerce and the public. The actions recommended in this report represent first steps in ensuring that the MTS, and intermodalism in general, has a meaningful influence on federal policies and decision-making processes. REFERENCE Abbreviation GAO General Accounting Office GAO. 2002. Marine Transportation: Federal Financing and a Framework for Infrastructure Investments. Report GAO-02-1033. Washington, D.C.