III. Safety

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Sep 9, 2013 - organizations united under the Alliance for Biking & Walking. We work to implement educational .... Co
The Honorable Secretary Anthony Foxx The Secretary of Transportation United States Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 September 9, 2013 Dear Secretary Foxx, Thank you for the opportunity to submit comments on the US Department of Transportation’s strategic plan “Transportation for a New Generation,” which lays out how the US Department of Transportation proposes to manage our transportation system from 2014 to 2018. We, the undersigned organizations, are state and local bicycle and walking advocacy organizations united under the Alliance for Biking & Walking. We work to implement educational programs, advocacy initiatives and awareness campaigns to create safer roads, stronger communities and accessible neighborhoods for everybody. We support the overriding priorities you have laid out for the Department, including making the US transportation system the safest in the world, improving the efficiency and performance of the existing transportation system and rebuilding the nation’s infrastructure “to meet the needs of the next generation of Americans.” We believe the following comments and suggestions can help the department meet those goals.

III. Safety 1. Safety performance goal and indicators The Department’s plan includes the goal of reducing roadway fatalities per 100 million VMT. We believe this goal will be stronger if: a) US DOT sets specific numerical goals for each of the sub-indicators, and b) Priority is given to develop a metric based on non-motorized miles traveled. The undersigned groups therefore recommend that the Department alter the performance goal to the following: • Reduce roadway fatalities by 50 percent by 2020 for each of the following sub-categories: o Passenger vehicle occupant fatalities o Motorcycle rider fatalities o Bicycle fatalities o Pedestrian fatalities 1

o Roadway fatalities involving larger trucks and buses 2. Proposed strategies to meet safety goals In its proposed strategies to reduce pedestrian, bicyclist and older driver fatalities and injuries, DOT has included several strategies we agree with. Most notably, the undersigned groups applaud the Department for proposing the following strategies: • Encouraging states to adopt policies and programs that improve pedestrian and bicyclist safety. • Providing technical assistance such as bicycle and pedestrian safety assessments to state, local and tribal governments. • Developing training programs for drivers, bicyclists and pedestrians. • Distributing technical guidance on improving bicycle and pedestrian safety through engineering, outreach and enforcement activities. While we are pleased to see biking and walking safety given specific attention, we strongly encourage the Department to separate active transportation modes from older drivers when considering safety. Because walking and biking safety differs strongly from older driver safety, it is imperative that these issue areas be given unique treatment. In order to ensure maximum success in truly improving safety on our roads network, the undersigned groups urge the Department to incorporate the following additional safety strategies: • Implement a Complete Street approach when designing safety measures, such as: o Ensuring intersection improvements benefit motorists, transit users, bicyclists and pedestrians; o Amending rumble strip policies to address the particular needs of bicyclists so as not to create additional safety hazards or deterrents to bicycling. • Focus on reducing speed as a crash factor, especially in metropolitan areas. • Study alternatives to the common practice of setting speed limits using the 85th percentile speed of free flowing traffic. • Implement MAP-21 performance measures that address non-motorized safety under FHWA Highway Safety funding. (The current proposed strategic plan suggests this strategy for motor vehicle safety but not bicycle and pedestrian safety). • Actively encourage investment in bicycling and pedestrian infrastructure that addresses system-wide safety issues. • Improve data collection for bicycling and walking. Specifically: o Improve data collection and analysis of use and crash data at the municipal, MPO and state level. (In the current proposed strategic plan, this strategy is suggested for motor vehicle safety but not for bicycle and pedestrian safety.) o Improve NHTSA’s data collection and analysis system to enhance bicycle and pedestrian crash data. (The proposed plan suggests this strategy for motor vehicle safety but not bicycle and pedestrian safety.) o Conduct a bicycle and pedestrian crash causation study to identify contributing

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factors for bicycle and pedestrian crashes and identify effective countermeasures based on evaluation and analysis of the study data. (There is currently a study on motorcycle crashes underway, but there has not yet been a comparable study for bicycle and pedestrian crashes.) o Support, conduct and encourage research on innovate design of bicycle facilities.

IV. Livable Communities 1. Livable communities performance goal and indicators The Department’s existing performance goal for encouraging livable communities entails improving networks that accommodate walking and biking “by increasing to 65 the number of states, MPOs, and/or plans that improve transportation choices for walking and bicycling by FY 2018.” This performance goal and accompanying indicator is, frankly, odd. There are already over 500 Complete Streets policies and even more bicycle and pedestrian plans already in states, metropolitan planning organizations and communities across the US. In light of this existing progress, the undersigned groups suggest that the Department alter the Livable Communities performance goal to the following concrete, measurable and ambitious goal: Increase bicycle mode share nationally to 5% by 2025 and pedestrian mode share nationally to 25% by 2025. Mode share goals for urban, suburban and rural communities may vary. Further, we suggest that the department include the following performance indicator: Set incremental bicycle and pedestrian mode share goals for the years 2015-2018. 2. Proposed strategies to meet Livable Communities goals The undersigned groups support many of the identified strategies under the Livable Communities goal. In particular, we thank the Department for incorporating the following strategies: • Performance measures o Developing national and local performance measures on livability o Continuing to encourage the impact of transportation investments on local land use, affordable housing and additional infrastructure needs; • Infrastructure investments o Focusing transportation spending to support complementary infrastructure investments that enhance livability o Addressing disproportionately high and adverse human health and environmental effects of transportation policies and programs on minority populations and low-income populations. 3

• Data collection and analysis o Developing and improving planning data and analytic techniques for planning and implementation of livability projects. In addition, the undersigned groups recommend the following strategies to ensure that states, regions and localities around the country maximize livability: • Adopt a Complete Street policy to ensure that livability is integrated into every program and project. • Institute annual or biennial travel surveys to accurately measure state and local bicycling and walking levels and better understand travel behaviors, trends and needs for all modes of transportation. • Set standards for coding transportation projects so that spending on bicycling and walking can be more accurately tracked. • Develop a framework for best practices for states and local jurisdictions to conduct audits and reports on bicycle and pedestrian facilities every 1 to 2 years. • Create a model system of accountability so that projects programmed with multi-modal accommodations in the STIP are built with those components. (For instance, a STIP amendment is required to change the scope of work concerning sidewalks and bike facilities.) • Research and disseminate best practices for retrofitting urban and suburban transportation facilities to consider all roadway users.

VII. Environmental Sustainability 1. Environmental sustainability performance goal and indicator There are currently no goals or indicators that address bicycling or walking under any of the Environmental Sustainability Strategic Objectives, an omission that the undersigned groups urge the Department to rectify. Currently, the strategic objective for environmental sustainability reads: “Avoid and mitigate transportation related impacts to climate, ecosystems and communities by helping partners make informed project planning decisions through an analysis of acceptable alternatives, balancing the need to obtain sound environmental outcomes with demands to accelerate project delivery.” The undersigned groups recommend that the Department incorporate the following performance goal for environmental sustainability: Institute a Complete Streets policy Further, we recommend that the Department incorporate the following performance indicator for that goal: Mode share increases in biking, walking and transit. 4

2. Strategies to meet environmental sustainability goals The undersigned groups recommend the following strategies to ensure that states, regions and localities utilize bicycling and walking improvements to mitigate transportation related impacts to climate, ecosystems and communities: • Develop training programs for federal, state and local transportation engineers on Complete Streets policies and practices. • Create a clearinghouse of best practices and innovative design for Complete Streets policies and practices.

VIII. Organizational Excellence 1. Organizational excellence performance goal and indicator The Department has included the following strategic objective in this section: “Build a capable, diverse, and collaborative workforce of highly skilled, innovative, and motivated employees by making DOT a workplace of choice through employee empowerment and engagement, learning and development, succession planning, workplace flexibilities, and a healthy and safe workforce.” In order to sustain a Department well equipped to regulate transportation for coming generations, the undersigned groups suggest that the Department incorporate the following performance goal: Retrain the next generation of transportation professionals to be truly multimodal. Further, we recommend that the Department institute accompanying performance indicators in the following models: Increase to X the percent of new hires with experience or education in multimodal engineering, planning and so forth. Increase to X the percent of existing staff receiving continuing education on designing, planning and building multimodal projects. 2. Strategies to meet organizational excellence goals The undersigned groups recommend that the Department incorporate the following strategy to achieve organizational excellence: • Develop and offer training programs in multimodal transportation for US DOT transportation headquarter and regional staff.

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Thank you again for the opportunity to comment on US Department of Transportation’s Strategic Plan. We look forward to working with you to implement the plan and improve our national transportation system for all users. Sincerely, Alliance for Biking & Walking

Bike Erie Erie, PA

National

Bike Maryland Maryland

Active Transportation Alliance

Bike Newport

Chicago, IL

Newport, RI

Alabama Bicycle Coalition

Bike Pittsburgh

Birmingham, AL

Bicycle Advocacy of Central Arkansas Central Arkansas

Bicycle Alliance of Washington Washington state

Bicycle Coalition of Greater Philadelphia Philadelphia, PA

Pittsburgh, PA

Bike Utah ADVOCATE - EDUCATE - RIDE www.BikeUtah.org

Utah

Bike Walk Connecticut Hartford, CT

Bike Walk Greenville Greenville, SC

Bike Walk Mississippi Mississippi

Bicycle Coalition of Maine

Bike Walk Montana, Inc.

Bicycle Commuters of Anchorage

Bike Walk Tennessee

Portland, ME

Anchorage, AK

Bicycle Indiana, Inc. Indianapolis, IN

Bicycle Transportation Alliance Oregon

Bike Austin Austin, TX

Bike Cleveland Cleveland, OH

Montana

Tennessee

Bike-Walk Alliance of NH New Hampshire

Bike&Walk Montclair Montclair, NJ

BikeDFW

Dallas-Fort Worth, TX

BikeHouston Houston, TX

Bikemore

Baltimore, MD

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BikeSD

San Diego, CA

BikeTexas Texas

BikeWalkKC

Kansas City, MO/KS

Greater Grand Rapids Bicycle Coalition Grand Rapids, MI

Health by Design Indiana

BikeWalkLee

Idaho Pedestrian and Bicycle Alliance

Lee County, FL

Idaho

Boston Cyclists Union

Iowa Bicycle Coalition

Greater Boston, MA

Iowa

California Bicycle Coalition

Kids on Bikes

Sacramento, CA

Colorado Springs, CO

California WALKS

League of Illinois Bicyclists

California

Illinois

Cascade Bicycle Club

League of Michigan Bicyclists

Seattle, WA

Chico Velo Cycling Chico, CA

Cleveland Touring Club Cleveland, OH

CompleteGeorge.org New York

Consider Biking, Inc. Columbus, OH

Cycle Therapy Rome, GA

Davis Bicycles! Davis, CA

Des Moines Bicycle Collective Des Moines, IA

Friends of Pathways

Jackson / Teton County, WY

GObike Buffalo

Lansing, MI

Lebanon Valley Bicycle Coalution Lebanon County, PA

Livable Streets Alliance Boston region, MA

Living Streets Alliance Tucson, AZ

Local Motion Burlington, VT

Los Angeles County Bicycle Coalition Los Angeles, CA

Marin County Bicycle Coalition Fairfax, CA

Massachusetts Bicycle Coalition Massachusetts

Buffalo, NY

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Michigan Environmental Council

Sonoma County Bicycle Coalition

Mode Shift Omaha

St. Paul Smart Trips

Napa County Bicycle Coalition

Transportation Alternatives

Michigan

Omaha, NE

Napa Valley, CA

Napa Valley Vine Trail Coalition Napa Valley, CA

New Jersey Bike & Walk Coalition New Jersey

New York Bicycling Coalition Albany, NY

New York Cycle Club New York, NY

North Carolina Active Transportation Alliance North Carolina

Palmetto Cycling Coalition Columbia, SC

People Power

Santa Cruz County, CA

Recycle-Bicycle, Inc Brooklyn, NY

Reno Bike Project Reno, NV

Ridge Prairie Trailhead Initiative Lebanon, IL

Sonoma County, CA St. Paul, MN

New York, NY

TRED Rome/Floyd County Rome, GA

Undriving Seattle, WA

Virginia Bicycling Federation Virginia

Walk Bike Glendale Glendale, CA

Walk Boston Boston, MA

Walk San Francisco San Francisco, CA

WALKSacramento Sacramento, CA

Washington Area Bicyclist Association Washington, DC

Wisconsin Bicycle Federation Wisconsin

WV Connecting Communities West Virginia

Wyoming Pathways Cheyenne, WY

San Luis Obispo County Bicycle Coalition Central Coast, CA

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