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Proposed Rule on National Performance Management Measures

Wednesday, September 07, 2016   (0 Comments)
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The Honorable Anthony Foxx
Secretary, U.S. Department of Transportation
Docket Operations
M‐30, West Building Ground Floor, Room W12‐140
1200 New Jersey Avenue SE
Washington, DC 20590

Re: Docket Number: FHWA‐2013‐0054, Proposed Rule on National Performance Management Measures: Assessing Performance of the National Highway System, Freight Movement on the Interstate System, and Congestion Mitigation and Air Quality Improvement Program

Dear Secretary Foxx: 

The Association of Pedestrian and Bicycle Professionals (APBP) greatly appreciates your support and leadership in developing connected multimodal transportation networks that are efficient, safe, and accessible for  people of all ages and abilities using all modes of transportation. 

APBP members throughout the United States work to make communities more walkable and bicycle-friendly. The APBP Board of Directors is comprised of international experts who specialize in active, sustainable transportation solutions. On behalf of our membership we are formally submitting comments regarding the FHWA‐2013‐0054, Proposed Rule on National Performance Management Measures: Assessing Performance of the National Highway System, Freight Movement on the Interstate System, and Congestion Mitigation and Air Quality Improvement Program.

The current proposal as it stands does not, in our opinion, adequately address walking, bicycling, and public transit performance measures, which we believe are critical to increasing the health, equity, and economic vitality of our communities.

We are confident that our goals are consistent with the goals of the U.S. DOT. We seek to create vibrant communities where people want to grow up and grow old, live, work, play and go to school. Studies have shown that investing in walking, bicycling, and public transit leads to more economic development and ultimately to higher levels of happiness. Notably, these investments also benefit low wealth individuals and families who often spend nearly a third of their income on transportation. 

People of all socioeconomic backgrounds, genders, races, and diverse demographics should have access to multiple viable transportation options. It is our duty as civil servants to provide sustainable transportation infrastructure that does not exclude people who do not or cannot afford to own and operate a motor vehicle. Further, it is our duty to increase the safety of our transportation system to better serve the most vulnerable roadway users – such as young children and the elderly – who walk, bicycle, or use public transportation. 

Cities and towns across North America are installing innovative bicycling, walking, and transit facilities, implementing Complete Streets policies and Safe Routes to School programs, and improving safety through “Vision Zero” programs that aim to eliminate traffic fatalities. Urban areas in particular are increasing in population, reversing a decades-old trend, and active transportation is especially suitable for our metropolitan areas. The increasing popularity of the walking, bicycling, and public transit movement cannot be denied. That is why APBP is so surprised and disappointed to see that the proposed NHS performance measures focus exclusively on motor vehicle delay and travel time. 

APBP can understand the desire to minimize congestion and reduce motor vehicle delay.  However, our membership believes that walking, bicycling, and mass transit are increasingly critical modes of transportation and need equal consideration. Active transportation is the key to the health of every American. People who walk, bicycle and use public transit are America’s eyes on the street, needed to help reduce crime. Better, safer, active transportation options can help to reduce America’s reliance on fossil fuels. 

The Federal Highway Administration recently published a Guidebook for Developing Pedestrian and Bicycle Performance Measures which highlights many alternative approaches for evaluating a transportation system. APBP urges use of this publication in finalizing NHS performance measures.

APBP recommends inclusion of the following points in future performance measures:

1. Vehicle Miles Traveled (VMT). Widening roads to meet Level of Service (LOS) standards only leads to induced demand and more calls to widen roads. APBP recognizes that motor vehicle delay performance measures may continue to play a role in transportation system evaluation, however, motor vehicle delay should not be prioritized above other goals.

2. Use second or third peak hour as the target for LOS. Cities are already using this measure, instead of focusing on a peak hour or a peak 15 minutes. Give local authorities the power to determine which peak timeframe they want to meet. Such a change in focus will lead to more equitable decision-making and allocation of transportation resources.

3. Prioritize walking, bicycling and transit use. Cities and countries that are doing this, as seen on the 2009 International Scan on Pedestrian and Bicyclist Safety and Mobility, enjoy higher levels of active transportation and reduced congestion and relay for all users of the transportation system. Gradually, cities in the U.S. are beginning to adopt this road user hierarchy. 

4. Roads that move freight must also support safe multi-modal travel. 

5. Shorten signal cycle lengths to reduce delay for pedestrians, bicyclists, and transit vehicles.

6. Reduce delays for people who walk, bicycle and take public transit.

7. Decrease the number of undivided multi-lane roads that pose difficult and dangerous crossings for people walking or bicycling.

8. Decrease bike/ped crash rates, particularly crashes that are fatal or result in serious injury.

Secretary Foxx, thank you for considering our comments. APBP is hopeful that the final rule will be more inclusive of the needs of communities our members and our transportation systems serve, including our walkers, bicyclists, and public transportation users, and will lead to a transportation system that is safer, healthier, and more livable for all.

Sincerely yours,

The Association of Pedestrian and Bicycle Professionals (APBP) Board of Directors

APBP Board member profiles can be found here:

201 E. Main St. Suite 1405
Lexington, KY 40507

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