However, BikeWalkLee is concerned, along with our national partners, that the measures are outdated and prioritize moving cars quickly, rather than measuring economic growth, safety, equity, and opportunity.
See the BikeWalkLee comments submitted to USDOT below:
August 16, 2016
U.S.
Department
of
Transportation
Docket
Operations
M-30,
West
Building
Ground
Floor,
Room
W12-140
1200
New
Jersey
Avenue
SE.
Washington,
DC
20590
Docket
Name:
National
Performance Management Measures; Assessing Performance of the
National Highway System, Congestion Mitigation and Air Quality
Improvement Program, and Freight Movement on the Interstate System
Docket
Number:
FHWA-2013-0054
RIN:
2125-AF54
Thank
you
for
the
opportunity
to
comment
on
Federal
Highway
Administration’s
proposed
performance
management measures.
BikeWalkLee
is
a citizen
based
community
coalition,
with 70
stakeholder
organization
supporters,
who work
to
raise
public
awareness
and
advocate
for
complete
streets.
BikeWalkLee 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,
where improving
safety
is
a key
goal.
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.
For some time, BikeWalkLee has advocated
for performance measures and targets for each transportation mode. As
a result, we are concerned about the proposed rule for its
inattention to modes other than the vehicle. The outcomes of these
performance measures will be to reinforce an already failing
transportation system that is focused on moving cars quickly.
Instead, these proposed measures should support the USDOT’s
commitment to transportation accessibility and complete streets that
serve all users of our system. In essence, the focus for these
measures should be based on the very human need for accessibility.
These comments are focused on the
measures outlined in the proposed rule document, including those
related to traffic congestion; on-road mobile source emissions;
freight movement on the Interstate System; performance of the
Interstate System; and performance of the non-Interstate NHS.
Congestion Measures.
BikeWalkLee supports the inclusion of performance measures to account
for congestion that include all modes. The measures should focus on
the different kinds of congestion that the traveler experiences when
using different modes. For example, a transit user will experience
delays if the vehicle (e.g., bus or rail) is at or over capacity
regardless of if the road it travels on is experiencing delay.
Conversely, if the roadway is experiencing delays, a transit vehicle
may or may not be “congested”. This requires that performance
measures be sensitive to the difference and relative advantage of
each mode within its unique context.
Air Quality.
BikeWalkLee is also concerned about the measures associated with
on-road mobile source emissions. The proposed rule limits that
applicability of this measure to only the Congestion Mitigation and
Air Quality Improvement Program (CMAQ) - funded projects. This is
problematic, as the opportunity to reduce emissions comes from
operations and capital projects. The rule, then, should recognize
this and measure emissions reductions from all CMAQ recipients,
rather than simply focus on CMAQ projects. In addition, this rule
ignores the reductions in greenhouse gas emissions that can come from
increasing other non-vehicular modes of travel (such as walking and
biking).
Accessibility.
BikeWalkLee is further concerned that the proposed rules miss out on
the important opportunity to measure accessibility. Accessibility is
often defined as the individual’s ability to reach their desired
destination, regardless of mode (foot, bike, or automobile). The
importance of this measure cannot be overstated. As changes are made
to the transportation network, accessibility is affected. For
example, increases in automobile mobility may decrease transportation
accessibility. This is especially true when major roadways are
constructed through urban areas.
To improve the proposed rule, BikeWalkLee
supports the revisions as proposed by Transportation for America in
their public comments on Docket No. FHWA-2013-0054. In addition, as a
member
of
the
League
of
American
Bicyclists,
our
organization
endorses
the
content
of
the
League’s
response
to Docket No. FHWA
2013-0054.
While these two organizations are able to
voice
the national
perspective
on
these
issues,
BikeWalkLee
understands
what's
at
stake
on
the
local
level.
Our
local
officials
will use these measures to prioritize projects and funding on the
ground. The consequences for the content of these measures are
significant at the local level, affecting our ability to implement
complete streets programs, as well as reduce safety risks to
pedestrians
and
cyclists.
We
need
our
federal
partners
to
provide
leadership
by
establishing the incentives
and
measures
that
will provide
accountability
for
all levels
of
government
to reach these goals.
Sincerely,
Margaret
Banyan
Margaret Banyan
Steering
Group
Member,
BikeWalkLee
a coalition
working
to
complete
the
streets
in Lee
County
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