To: FHWA
Docket Name: National Performance Management Measures; Highway Safety Improvement Program
Docket Name: National Performance Management Measures; Highway Safety Improvement Program
Docket Number: FHWA-2013-0020
RIN: 2125-AF49
Thank you for the opportunity to comment on Federal Highway Administration’s
proposed national performance measure for safety.
BikeWalkLee is a citizen based community coalition, with 62
stakeholder organization supporters, that works to raise public awareness and
advocate for complete streets and is dedicated to improving the quality of life
and mobility in Lee County. Lee County
was recently awarded a TIGER V grant for its complete streets initiative
project, and improving safety is a key goal of this project. Lee County's traffic safety record for
bicyclists and pedestrians is in the top 10 worst in the state, and Florida is
the most dangerous state in the country for pedestrians and cyclists. Twenty-three percent of recent roadway
crashes in Lee County involved injuries or fatalities to bicyclists or
pedestrians--nearly double the national average.
We support the
inclusion of a non-motorized safety performance measure and believe such a
measure is necessary to address Florida and Lee County's serious bike/ped
safety problem. When
MAP-21 was enacted, we were excited because we saw the greatly enhanced safety provisions in MAP-21 as an
opportunity to try to get Florida to better address this problem, and we have
communicated with USDOT over the past two years about the importance of
providing us with the tools to make this happen--to develop national
performance measures for the new safety program that require performance
measures and targets for each mode of transportation.
Without these by mode targets, efforts at the state and local levels to
improve bike/ped safety will be hampered. Back in 2010, BikeWalkLee
undertook a major study of Florida's Safety Plan and HSIP program and found
that Florida's safety plan only established one quantitative goal--to
improve the safety of Florida’s surface transportation system by achieving a 5
percent annual reduction in the rate of fatalities and serious injuries . Using this one measure that was not disaggregated by
type of user or by fatalities vs. injuries allowed FDOT to proclaim in each
year's annual report to USDOT that they were achieving if not exceeding their
safety goal; and therefore, Florida was in great shape when it came
to safety on its roadways! Clearly, having only
this one goal masked what was really going on--an increasing share of all
traffic fatalities that were bike and pedestrian and continuation of Florida's
dubious distinction as the most dangerous state in the nation for cyclists and
pedestrians. Further, the safety goal
was structured in a way to be achievable without policy or funding
intervention. For example, the overall reduction in traffic fatalities
and serious injuries that has occurred can be largely attributed to automobile
safety improvements, the economic downturn, and the reduction in the number of
miles driven.
In the past
two years, the Florida Department of
Transportation has made improving bike/ped safety a top priority and has
undertaken a statewide bike/ped safety campaign. Last year FDOT adopted the Florida Pedestrian
and Bicycle Strategic Safety Plan (PBSSP) to support Florida's Strategic
Highway Safety Plan (SHSP) which takes the 5% overall goal and specifically
calls for a 5% annual reduction in serious injuries and fatalities for pedestrians
and cyclists. Without having a federal
performance measure for bike/ped fatalities and injuries, there's no guarantee
that Florida will continue with its measures.
We need our federal partners to
show leadership on this issue. With
both Secretary LaHood and Secretary Foxx committed to placing a top priority on
improving bike/ped safety, it's
disappointing to see this strong policy position not supported by one of the key tools that the federal
government has--performance measures and accountability for delivering results
with federal dollars.
As a member of the League of American Bicyclists, our organization
endorses the content of the League’s
response to FHWA Docket 2013-0020. While the League is able to voice a
national perspective on this issue, BikeWalkLee understands what's at stake on
the local level. Our local officials
adopted a countywide bike/ped safety action plan last Fall to focus on this
problem, setting annual targets for reducing bike and pedestrian fatalities and
serious injury rates, with a zero fatalities vision. With over 23% of our traffic fatalities being
pedestrians and cyclists, we need our federal partners to provide leadership by
setting a national goal to make biking and walking a safe transportation option
and to set performance measures that will provide accountability at all levels
of government for reaching those goals.....
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