If a person uses a trail to get to work or school, and no one is around to measure the trip, do they count?
That is the question RTC has asked in response to a new performance measure rule proposed by the United States Department of Transportation (USDOT)—and our answer is YES!
Earlier this year, USDOT finalized a performance measure rule regarding safety, including some important requirements that state and local governments track pedestrian and bicyclist fatalities and injuries. Following that rule, on April 22, USDOT released a Notice of Proposed Rulemaking (NPRM) regarding four additional transportation performance measures that state departments of transportation and metropolitan planning organizations (MPOs) will be required to track. Three of the four performance measures impact trails and active-transportation networks:
- Congestion reduction on the national highway system
- Reliability of the surface transportation system
- Environmental sustainability
Congress included this performance management program as a requirement of the 2012 transportation bill, Moving Ahead for Progress in the 21st Century (MAP-21), to understand how federal dollars are spent, with the goal of increasing funding accountability and transparency. It’s a worthy goal, but the rule proposes outdated solutions to the question of how states and MPOs should track all three of these performance targets. As a result, the new rule will fail to make sure that our transportation system works for all its users, including trail users. So how does the rule fall short?
Counting People or Counting Cars?
First, the proposed methods for tracking reliability and congestion focus solely on how the system works for single-occupancy vehicles, e.g., cars, and enables them to move faster. It ignores users of other modes, such as bus and transit riders, and people who use trails and active-transportation networks. The NPRM focuses on two measurements, which are essentially the same: travel times experienced by traffic, and excessive delay for automobiles. The calculation of delay is based on how fast cars are able to go on highways and other roads. By focusing on how fast it takes to drive from one place to another, the rule ignores the important role that other methods such as walking or biking can play.
A better way to measure system performance and congestion would look not just at how quickly cars are able to travel on a stretch of road, but how people are able to access the places they need to get to every day, whether they do it by automobile, by transit, by bike or on foot.
USDOT should consider not just how quickly a person can drive a mile, but how well the highway system is integrated with other modes and how well the whole transportation network allows them to get to the places where they work, live, shop and play. RTC supports revising this rule to take into account a broader view of accessibility through the national highway system.
Second, while the performance measure for environmental sustainability requires that local and state governments track emissions of several key pollutants from automobiles, it is missing one important pollutant: greenhouse gas emissions. Tracking of greenhouse gases would help ensure that transportation planners work toward a comprehensive transportation network that pollutes less and includes trails and active-transportation networks.
Changing the Proposed Rule
The NPRM provides 120 days for individuals and organizations to submit comments and suggest changes. USDOT has requested feedback about whether the methods of measurement are adequate or should be reconsidered. For example, they ask: Should states and local governments track greenhouse gas emissions, and how? Should they track transportation accessibility to jobs and housing as part of their examination of the performance of the National Highway System, and if so how?
This comment period is an opportunity to tell USDOT that people who use trails DO matter! Now is the time to make our voices heard by telling USDOT that those who walk, bike or use trails to get to their destination should be counted, and that the performance measures should be about more than just cars.
Comments must be submitted by Aug. 20, and information about how to submit comments is available here.
You can also encourage supporters to sign our online petition by Aug. 18. We'll deliver the signatures to USDOT by the deadline.