ADOT ‘An Aone Menagement stem Age, sation tive Se ton rs uly 32, 2019 Mr. Osmahn kad General Services Administration 50 United Nations Plata, 2345 Mailbox #9 San Francisco, CA 98102 Dear Osmabm: (on behalf ofthe Arizona Department of Adminstration, thank youfor giving us the opportunity to express ADOT’s concerns about proposed bus and truck inspections faites at the Arizona-Mexico border. An Environmental impact Statement forthe construction ofthese facilities is curently being scoped by the General Services Adminstration on behalf ofthe Federal MatorCarir Safety Administration (FMCSA). ‘ADOT favors a “ne bulla” seenato for Arizona's three major commercial port of entry 'As you know, FMCSA and ADOT have a unique partnership that Neos ensure the safety of trucks and rivers crossing the border. Ourtwo agencies shae the mission of inspecting commercial vehicles and config the credentials of ervers as they enter the state, Unike mest other border states, Arizona, actully has FMCSA offers housed in state-owned ports of entry in Nogales and San Ls. ‘Although the agencles share space, they haven't always used the same approach to truck safety Inspections. That led to many ofthe drivers who cary erucal products back and forth complaining about unnecessally redundant inspections that dia’t promote safety and instead slowed down Following Governor Oucey's directive to use streamlined process improvements ae away to enhance effiiency and safety, ADOT partnered with FMCSA to establish a share, risk-based approach to Inspections. Today, trucks and drives with proper up-to-date credentials can pass quickly and get on the road, Those without current safety stickers or appropriate credentials, or where the truckhas a ble defect, are promptly stopped and thoroughly inspected, and forced out of service if necessary. In February of 2019, ADOT signed @ Memorandum of Understanding with MCSA codfying this approach ‘and extending the lease arrangement with FMICSA for five years. ADOT was and remains more than Willing to ciscuse an extended lease period Further, fllowing a recent feasibility study fora new port of entry in Douglas, ADOT and FMCSA have ‘agreed to explore shared space a a potential new feciity on Oauglas as well, where ADOT would likely be a tenant in FMCSA's federal space once that new por is funded ‘ARLONA DEPARTMENT OF TRANSPORTATIONIn adlition tothe obvious costs savings that come to both the state and federal governments from sharing space, there i one additional benefit to having the state and federal inspectors work together. Wile FMCSA has fllyicensed inspector, with fll authority to take unsafe trucks or drivers off the ‘oad, only ADOT has fuly sworn ofcers in those positions, meaning tat incase of a significant security Issue ADOT has fully trained and armed officers on site. Given the excellent partnership and many benefits that ensue from shared space and a common approach, ADOT was quite surprised when FM(CSA andthe General Services Administration announced their intent to embark on a programmatic Environmental Impact review to build brand new FMCSA. facitis at Arizona's major commesil ports of entry including the two where FMCSA I currently co located with ADOT. Separate facilites for FMICSA mean aretur to the bad old days of redundant Inspections, uneven enforcement, unnecessary construction and maintenance costs, and slower crossing times for legitimate commerce. The addition of new FMCSA facilities doesn’t even remove the burden to ADOT of needing to have officers on the border. Only ADOT officers can weigh trucks to ensure that they are within legal state weigh limits, and only ADOT officers can isue necessary state permits. So the shift will stl require, by law, that ADOT officers remain on the border and have spac in which to operate. ‘The addition of eedundant FMCSA faites wil ultimately show no improvements in operational effleiencies, result n redundant enforcement for legal commerce, and cst taxpayers more -with no isernable benefit to safety oF enforcement. Further, Arizona's border stakeholers, including trucking companies, produce and maquila intrest, port authorities, andthe three border communities, ae al opposed the construction of new facies for FMCSA, for alo the reasons neted above We respectfully request that FMICSA to drop this ine of inquiry, and that FMISA work with ADOT to scuss any future budget requests for new faclties where existing partnerships and long-term leased facies are already i place. Further, we request that wherever new port of enty facilities are under consideration (such as Douglas that FMICSA be required to work fist with ADOT to find a way to share ‘their responsibilities na cost effective and efficient manner rather than setting up duplicative facies and processes. ADOT Is doing its part to support Arizona's ports of entry. Our efforts include not only improved inspections, bt also the training of commercial drivers onthe expectations that Avzona has for divers ‘rossng the border. Drivers who have undertaken this traning have an out of service ate of nearly zero. These innovative approaches have made Arizona's pots the preferred routes of logistics providers throughout Mesico, with many more ruck crossing fom Chihuahua, Baja California, and other Mexican states‘Thank you forgiving us the opportunity welgh non this important issue. if you have specific ‘questions, please contact Gall Lewis at 602 531 3585 or glewis2@azdot.go. Sincerely, ee feo Deceit pening er Ce: Anthony Kleppe (Anthony Keppe@es2 gov)