Engineers to U.S. DOT: Transportation Is About More Than Moving Cars

Throughout the current proposed rulemaking on NHS performance, traffic congestion, freight mobility, and air quality, an underlying theme is apparent: these measures speak largely to the experience of those in single occupancy vehicles (SOVs). While such a focus is understandable in the short-term, owing largely to the current availability of data from the NPMRDS and other national sources, ITE and its membership feel that FHWA should move quickly within the framework of the existing performance management legislation to begin developing performance measures that cater to multimodal transportation systems.

The first step in this process is instituting a program to develop standards and procedures for data collection within this alternative modes of travel, an effort which ITE feels should be undertaken by FHWA and its USDOT partner agencies concurrent to the final performance management rulemaking under consideration. Once this multimodal framework is established, FHWA can work to develop a more comprehensive and holistic set of performance measures that accommodate multiple modes of transportation, while achieving secondary effects of improved public health, community livability, and economic development.

While ITE is supportive in moving forward with the majority of the proposed measures as the first step in this evolutionary process, we do believe FHWA should postpone the adoption of an urban congestion measure until such time as this measure can represent all users of the system. The singular focus of the current proposed measure on vehicle-based travel may have the unintended consequences of focusing investment on the movement of SOVs at a time when the transportation industry has begun to aggressively support shared services and transportation choices. Rather than expending limited FHWA, State and local resources on implementing a measure of questionable value, we respectfully request that FHWA direct those resources toward the collection of multi-modal data and the establishment of multi-modal and person-based measures.