Harris Boulevard in Charlotte, NC. Photo by CLTPathmaker via Flickr.
Get out your commenting pens, folks, because the U.S. Department of Transportation’s proposed rule for measuring progress on safety needs a lot of work.
In the 2012 transportation law, MAP-21, Congress directed the DOT to set measures of progress in a number of areas that could be used to hold transportation agencies accountable. The first one out of this gate last week was safety. [See the full rule as published in the Federal Register here.]
It should have been a triumph for people concerned about the lives and well-being of all users of the road network. For the first time, Congress emphasized that state DOTs would need to significantly reduce the number and rate of deaths and injuries on our roadways. And the DOT’s rhetoric in the new rule suggests that as their intention.
The reality, though, is that the proposed rule is toothless. It:
- Fails to set performance targets for reducing deaths among non-motorized users separate from motorized users
- Requires agencies to meet only half of the four targets
- Permits them to set “pass” levels that actually could allow deaths and injuries to increase
Underlying several of these issues is the decision to judge progress according to trend lines that are granted a huge margin of area – and the trends themselves are based on projections of vehicle miles traveled that are notoriously unreliable. [For a more detailed, technical analysis look here.]
There are some bright spots. Agencies must account for safety on the entire network, not just the major, federal-aid roadways. The rule pushes agencies to begin linking crash data with data from hospitals and emergency responders to better understand more about the kinds of injuries and causes of death. It proposes a consistent definition of “serious injury” across the country. And, importantly, it allows states to do more to protect their residents and visitors.
As we hope many other concerned organizations and individuals will do, we will submit comments suggesting critical changes to make these performance measures more meaningful. We will urge DOT to:
- Work toward meeting all four performance measures required by law
- Set real goals that are clear and forward-looking, not based on squishy trend forecasts
- Establish separate measures for motorized and non-motorized travel
- Encourage states to put the requirements into effect as soon as possible and not wait for other performance rules to be final
You can add your voice. Right now, you can ask your members of Congress to cosponsor a bill that specifically requires separate motorized and non-motorized performance measures. You also can submit your comments directly to the Federal Register.
Stay tuned, though: we’ll help provide you with opportunities to learn more about the proposed rule, our analysis, and suggested comments to improve it.