Monday, August 22, 2016

BikeWalkLee comments on USDOT proposed performance measures

The U.S. Department of Transportation has released draft performance measures that sets the requirements for how states and metropolitan areas measure traffic congestion. These measures are important for transparency and accountability in transportation funding.

However, BikeWalkLee is concerned, along with our national partners, that the measures are outdated and prioritize moving cars quickly, rather than measuring economic growth, safety, equity, and opportunity.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 Leagues 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.


Margaret Banyan

Margaret Banyan
Steering Group Member,
BikeWalkLee a coalition working to complete the streets in Lee County

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