Daniel Cohen
Assistant General Counsel for Regulation and Legislation
U.S. Department of Transportation
1200 New Jersey Avenue, SE, West Building, Ground Floor, W12-140 Washington, D.C. 20590-0001
RE: Docket No. DOT-OST-2025-0468, Comments on Advancing a Surface Transportation Proposal
Dear Assistant General Counsel Cohen:
The Coalition to Protect America’s National Parks submits these following recommendations on the U.S. Department of Transportation’s (DOT) request for ideas, comments and information for consideration in the development of the next surface transportation authorizing legislation as it relates to the National Park System.
For more than a century, our national parks have remained America’s favorite places, important pieces of our natural, historical and cultural heritage set aside for future generations to explore and enjoy. And the National Park Service depends on funding through the Highway Trust Fund or other sources to improve park transportation assets to ensure visitors can enjoy the parks and park resources are preserved for future generations.
The National Park Service (NPS) owns and maintains 6,600 miles of paved roads, 7,300 miles of unpaved roads, 6,300 paved parking areas, 1,800 bridges and tunnels, around 1,000 miles of trails, and 100 transit and ferry systems. But as visitors enjoy our parks, they find the roads, bridges, and pathways throughout parks and nearby communities need major repair after decades of use.
According to the NPS, the current replacement value of the NPS transportation assets is $51.5 billion. NPS estimates a need of $730 million a year to maintain its transportation assets, far short of the current $458 million available.
They not only protect unique historic and natural resources but also support the national economy with more than fifteen dollars in economic activity for every dollar invested. In 2023, 325 million park visitors spent an estimated $26.4 billion in local gateway communities while visiting NPS sites across the country. These expenditures supported a total of 415,000 jobs. In addition, America’s outdoor recreation economy supports over 5 million American jobs and contributes $1.2 trillion in annual economic output. In 2023, there were over 66 million international arrivals to the United States and research indicates that national parks were a huge tourism attraction for those visitors.
Therefore, we support the following funding and policy recommendations:
Federal Lands Transportation Program
Increase the Federal Lands Transportation Program (FLTP) program for parks to at least $550 million per year and exempt the program from lop-off reductions. The FLTP was specifically established to support the transportation assets owned and maintained by federal land management agencies, including the NPS. The annual obligation limitation, or lop-off, reduces the funding for the NPS by approximately 9.5% annually. We request that FLTP be exempt like other programs, such as those listed in P.L. 114-94 §1102(b).
Examples of recently funded projects include rehabilitating the Gatlinburg Tunnel in Great Smoky Mountains National Park, restoring Mojave National Preserve's Kelso Cima Road, repairing historic trails and bridges in New River Gorge National River to name a few.
Federal Lands Access Program
Increase the Federal Lands Access Program (FLAP) funding to at least $345 million per year. The program provides access to sites and recreational opportunities that are adjacent to or within federal lands. FLAP is a critical funding source that provides incentive to state and local entities to provide additional dollars that improve roads and transit to and from national parks. The funding is prioritized for projects in high-use recreation sites or are federal economic drivers.
Parks that benefited from FLAP funding in Fiscal Year 2023 include Canyonlands National Park, Cuyahoga Valley National Park, Denali National Park, Flight 93 National Memorial, Grand Teton National Park, Hot Springs National Park, Johnstown Flood National Memorial, Little Rock Central High School National Historic Site, Mammoth Cave National Park, Minuteman Missile National Historic Site, Olympic National Park, Pictured Rocks National Lakeshore, Timucuan Ecological and Historic Preserve, Wrangell-St. Elias National Park and Preserve, Yellowstone National Park, Zion National Park.
National Significant Federal Lands and Tribal Projects Program
Increase National Significant Federal Lands and Tribal Projects Program (NSFLTP) funding to at least $400 million dedicated funding per year with no less than half dedicated to public lands. NSFLTP provides funding for the construction, reconstruction, and rehabilitation of nationally- significant transportation projects within, adjacent to, or accessing federal and tribal lands. This program provides an opportunity to address significant challenges across the nation for transportation facilities that serve federal and tribal lands. The program receives $55 million in dedicated funding and is authorized at $300 million through the bipartisan Infrastructure Investment and Jobs Act. However, Congress has not provided appropriated funding in recent years.
This popular and necessary funding stream for federal lands and tribes addresses massive infrastructure projects needing large, one-time investments. The NPS transportation program has identified over 40 needed megaprojects in 18 states, with a total estimated cost of $2.4 billion.
Recent projects include replacing a significant portion of the buses at Grand Canyon and Zion National Parks, as well as supporting the restoration of the Tamiami Trail in Everglades National Park and rehabilitating a section of the Natchez Trace Parkway.
Emergency Relief for Federally Owned Roads
Increase the Emergency Relief for Federally Owned Roads (ERFO) funding to at least $200 million a year. The ERFO funding is critical in addressing damage caused by more frequent and devastating severe weather and natural disasters in national parks. In 2023, ERFO supported projects at parks including Olympic, Yosemite, Death Valley, Yellowstone and Delaware Water Gap. However, the funding amount is insufficient and its dispersal inefficient.
Expand Eligibility
Authorize federal lands to directly and explicitly compete for funding in the BUILD, INFRA, Bridge Investment, Wildlife Crossings Program, Culvert AOP, Safe Streets for All, highway safety programs and national priority safety programs without requirement for sponsorship, partnership or joint application from or with a State DOT. Also, ensure that NPS transit systems are eligible to receive federal funding from Title 49 programs.
Thank you for considering these comments. Please do not hesitate to contact us with any questions.
Sincerely,
Philip Francis
Chair, Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE Unit 77436
Washington, DC 20013