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League Comments on FHWA Draft Performance Measures

The following are comments submitted by the League to the U.S. Department of Transportation on the Federal Highway Administration’s recent draft performance measures.



April 27, 2016


The Honorable Anthony Foxx


U.S. Department of Transportation

West Building, Room W12-140

1200 New Jersey Ave. SE.

Washington, DC 20590


RE: Docket Number: FHWA-2013-0054

League of American Bicyclists comments on National Performance Management Measures; National Highway System Performance, Congestion Management and Mobile Source Emissions


Dear Secretary Foxx:


The League of American Bicyclists represents the tens of millions of Americans of all ages who ride bikes every year. Founded in 1880, the League has more than 300,000 members and supporters in more than 900 affiliated state and local bicycling organizations, including 20,000 individual members and 5,000 bicycle safety instructors.


Thank you for the opportunity to comment on the Federal Highway Administration’s (FHWA) draft performance measures. The League of American Bicyclists (League) appreciates the work of the Secretary and the Department to invest in smart cities, bicycling and walking safety, and in its Ladders of Opportunities initiative. We believe the focus on these programs improves the transportation system for everyone using it and improves connectivity and access to the transportation disadvantaged, especially to those who have less access to single occupancy cars.


In this particular rule, the League appreciates the rules thorough description of the measures, including the acknowledgement that the rules would be stronger if they measured networks and included transit, bicycling and walking trips. The League agrees with this assessment.


By focusing all of the measures on delay and travel time of automobiles, FHWA limits the ability of metropolitan areas and states to measure the movement of people and instead focuses on vehicles. By measuring both congestion and the performance of the National Highway System (NHS) using similar measures, the rule creates unintended consequences for all other users of the road.


The discussion on networks is also very important. When measuring the value of projects built using Congestion Mitigation and Air Quality (CMAQ), or other funding it is critical to measure how those projects may complete or enhance networks. The reduction in emissions and/or congestion created by improving transit, bicycling and walking projects that connect destinations will be larger than just the few miles of that project. For a full accounting of the benefits the rule must include the full benefits of connecting communities with destinations.


The League contends that it is possible to measure reliability of the NHS, and the benefits to slowing congestion, for modes other than cars using existing practices. While these measures may not be perfect, cities and states are already using formulas to do this that could be adopted until more precise measures can be created.


It is a much bigger oversight to not include these trips and projects at all than to include current measures that can be improved on in the future.


National Highway System Performance Measure


The League of American Bicyclists requests that Federal Highway Administration revise the NHS Performance Measure to include a reliability measure for all modes of transportation. The reliability for bicycling and walking has been recognized to mean safe, accessible passage.


Congressional Intent

In the FAST Act Section 109(c), Congress made clear that states must consider all modes and users in the building and reconstruction of NHS projects. In fact, Congress took deliberate action to strengthen the language in the FAST Act from “may take into account” to “shall consider.”


Given that Congress meant for the projects to consider the needs of all modes of transportation in the building and reconstruction of NHS projects, it is inconsistent for FHWA to measure the performance of the system in a way that ONLY measures reliability for one mode.


The rule suggests that performance of the NHS should be measured by reliability, and defines reliability for as certainty for time travel on longer trips. Trip time for bicycling and walking, has  proven to be predictable. For people biking, walking and accessing transit, reliability is much more about having regular safe access to use the road and to be able to safely cross it.


Data Collection: Ability to measure reliability

A number of cities, states and FHWA itself have set standards for how to measure safe and accessible passage for bicyclists and pedestrians based on road characteristics. We believe that the performance of the NHS must include a measure on the reliability of the NHS to meet the needs of bicyclists, pedestrians and transit users as well.


We appreciate FHWA’s goal of keeping the measures simple and efficient, but believe there can be a mid-point between accurately accounting for all users and being easy to use. The League would be happy to work with FHWA to explore these options or others for measuring all users of the National Highway System.



Measuring Traffic Congestion


The draft performance measure for congestion uses “annual hours of excessive delay per capita.” is startlingly similar to the reliability measure for NHS performance, despite the fact that this measure is measuring congestion across a metropolitan area versus a specific road system. Measuring the delay for drivers only may create a disincentive to promoting and maintaining safe and accessible transportation choices.


The rule does not give credit to a state and metropolitan area for the work they’ve done to reduce delay by people who are NOT traveling in single occupancy vehicles. Several Metropolitan regions and states have instituted goals to: a) reduce vehicle miles traveled, b) reduce single-occupancy vehicle miles or trips traveled, and/or c) goals to increase mode share of biking, walking and transit. To create a congestion measure that does not support these goals will interfere with established state and local goals. Almost forty percent of states have goals to increase physical activity through their transportation policies, which supports all the above goals while reducing congestion.


To make this rule more compatible with these goals, a new measure should be added to account for people traveling by modes that reduce congestion- transit, bicycling and walking.  The measure should not be focused on addressing congestion on sidewalks, in bikeways and on transit as suggested in the rule, but rather to measure the value these projects have to reduce congestion by taking single occupancy vehicles off the road.


Replacing one of the existing measures with one that measures all commuters and travelers would finally establish the expectation that our transportation systems is meant to improve connectivity across a system for everyone regardless of travel mode; this would also give states credit for investments to expand, promote and maintain all facilities necessary to reduce congestion.


On-road Mobile Source Emissions


For the most part the rule continues current practices for measuring pollutants and the reduction in pollutants CMAQ projects can make. 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.


Measuring Greenhouse Gas Emissions

The League also supports the inclusion of greenhouse gas emissions both from tailpipes and from construction of new projects. The transportation system is responsible for 23 percent of the country’s emissions, and in order to meet the goals and commitments made at the Paris COP we need to start measuring and reducing emissions.



The League very much supports the Secretary’s goal to create a transportation system that connects, rather than divides, people with jobs, schools, healthcare and other destinations regardless of income or car ownership. However the League is concerned that this rule, as it stands works against that goal. By only measuring time travel for vehicles (whether that be delay or reliability) the goal leaves out a significant portion of the population who depend on transit, biking and walking.


The League believes that there are interim options to include all modes in performance measures regarding NHS reliability, congestion mitigation and air quality; and would welcome the opportunity to work with FHWA and others to define those options. By including all modes of travel, this rule will better reflect the needs of everyone who depends on our transportation system.

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