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Federal performance measures ignore biking

The US Department of Transportation released new performance measures last week to measure traffic congestion, air quality and road system performance. The new rules suggest measuring travel time for cars only.  Learn more about the League’s response and how you can help. 

Join us on Twitter on Friday, April 29 ,at 11am ET for a #bikechat to learn more.

Make sure to take action at to show your support for our comments.


The US Department of Transportation just released a draft of its performance measures for:

  1. Reliability/ performance of the National Highway Systems.
  2. Traffic Congestion
  3. Air quality/ mobile source emissions
  4. (Also Reliability/Performance of the Interstate and freight- but I have not included those here)

The measures proposed in this rule focus on single occupancy vehicles, how reliable their trips are, and how much delay they experience. None of the proposed measures include anything about non-motorized travel. To be fair, there is some discussion (in a 423-page announcement) of how they don’t know how to measure biking and walking. It seems like a non-sequitur given Secretary Foxx’s commitment both to biking and walking safety and accessibility and to his commitment to make transportation something that helps people connect to their communities and opportunities.

It’s Déjà vu

Remember the safety performance measure?

In the first draft of the safety measure FHWA released they argued that there were no good ways to measure bicycling and walking fatalities and serious injuries because we don’t have the ability to measure those fatalities versus miles traveled. Their answer was not to measure them at all.

Guess what- Thanks to the comments of over 11,000 of you, our allies in Congress, and several health, safety and transportation advocates — they were able to find a way and now there is a bicycle and pedestrian safety performance measure. Throughout his Tenure, Secretary Foxx has been an advocate for improving biking and walking safety.

Now FHWA argues that they do not have a measurement for road performance that is multi-modal, and they do not have a congestion measure that takes into account all the people NOT driving single occupancy cars. Their main argument is that they haven’t included these transportation modes in the past, they should be exempt from doing so now 

But we know that if you don’t get counted, you don’t count. The danger of only measuring for one mode is the unforeseen consequences to the people that choose other modes of transportation.

Let’s take these three measures one at a time.

Performance of the National Highway System (excluding the interstate).

The National Highway System, includes both the interstate and other major roads, including some arterials and main streets. To measure how well the system is performing Congress broke this measure into two- one to measure the interstates, which is what we often think of as highways, and the other to measure off interstate major roads. [pictures here]

Bicyclists need to weigh on the NHS, non-interstate as these roads are critical to building safe networks and safe travel across communities.

The draft rule the Federal Highway Administration proposes conflates performance of the National Highway System (NHS) for all traffic with travel time reliability for motorists. If a motorists usual morning commute is 30 minutes, it should be 30 minutes every morning. For people traveling via motorized travel that may work, but for non-motorized travel, reliability has much more to do with access, safety and comfort.

To create a performance measure for the NHS that does not consider all modes is in conflict with the the transportation law, the FAST Act, which was signed into law in December 2015. In the FAST Act, Congress included complete streets language, requiring states to consider all modes of transportation when constructing, reconstructing, resurfacing, restoring or rehabilitating the National Highway System.

The danger of a performance measure that only measures travel time reliability is that a state, in an effort to meet its goals on this performance measure may make changes to increase average travel speed that make biking, walking or traveling to the bus stop significantly less safe thus cutting off access for other modes.

There needs to be an additional measure that measures performance or reliability for those outside of cars. While reliability for motorists is measured by travel time, reliability for bicyclists and pedestrians is much more a measure of access, comfort and safety. There are many guidelines already in use by cities, state DOTs and FHWA itself to determine when roads or corridors have or need specific accommodations for bicycling and walking based on average daily vehicle volume and speed limits.

Reliability for biking and walking can be, and is measured. These measures may not be perfect, but they are workable option while FHWA improves on the model.

Traffic Congestion

The draft performance measure for congestion uses “annual hours of excessive delay per capita.”  The rule basically says sets a baseline speed of 35 mph on interstate, and 15mph on other roads. If cars are traveling more slowly than these speeds, the additional travel time is counted as delay. The sum of that time is divided by the number of people living in the urban portion of the metropolitan area.

The rule does not include a measure of the people who may be reducing delay because they are NOT traveling in single occupancy vehicles. In cities or states where which have a goal of reducing vehicle miles travelled, measuring the number of people using non-SOV travel should be included.

When making determinations for CMAQ dollars it’s critical to look at how a project creates or completes a network. The ability of a project to lower emissions is not just in the miles of that project but in the connections that will make more travel trips by clean transportation possible.

Air Quality/ Mobile Source Emissions

The rule will require states and MPOs to monitor and reduce emissions of pollutants already covered by the Congestion Mitigation and Air Quality Program. The big question FHWA poses in this document, should they be measuring greenhouse gas emissions?


 To be fair, the rule asks several in-depth questions about if they measure GHG, which emissions they should be measuring:

  • The emissions from the tailpipe or should they consider the ghg from power plants used to create the electricity used in electric cars?
  • Should they include emissions from transportation construction sites?
  • Should the rule effect all states and metropolitan areas or just some ones? 

I am not an expert in these answers, (and will get advice from partners in the environmental world that are more knowledgeable on this one) but it seems to me the answer is measure everything we can. Let’s get a baseline so we can start impacting it. After all, according to the Paris agreement we are going to have to drastically reduce these emissions — and do so quickly. 


It’s striking to me, though, that they are asking questions about, and are willing to consider measuring GHG’s from construction sites and power plants but they can’t figure out, nor do they even ask help with, measuring reliability for people walking and biking!


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