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June 15, 2010 - ASCE Comments - on the Department of Transportation Strategic Plan for FY 2010-2015

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The American Society of Civil Engineers (ASCE) is pleased to offer the following comments
regarding policy recommendations in the U.S Department of Transportation’s Strategic Plan for
Fiscal Years 2010- 2015, which organizes the department’s goals for the next six years into five
main areas: safety, maintenance of existing transportation infrastructure, fostering economic
competitiveness, developing livable communities, and achieving environmental sustainability.

ASCE, founded in 1852, is the country’s oldest national civil engineering organization
representing more than 144,000 civil engineers in private practice, government, industry, and
academia dedicated to the advancement of the science and profession of civil engineering. ASCE
is a 501(c)(3) non-profit educational and professional society.

ASCE commends the Department of Transportation for the ideas present in the Strategic Plan,
especially a renewed focus on the safety of the nation’s transportation systems, the desire to
bring infrastructure back into a state of good repair, and the Livable Communities initiative to
link national transportation policy and investment to complementary state, metro, and local land
use policies.

ASCE released the 2009 Report Card for America’s Infrastructure last year with the nation’s
infrastructure graded at a “D” with an estimated $2.2 trillion required in order to bring all
categories of our infrastructure into a state of good repair. The Report Card also poses 5 Key
Solutions to improve our nation’s infrastructure: increasing federal leadership in infrastructure;
promoting sustainability and resilience; developing federal, regional, and state infrastructure
plans; addressing life cycle costs and ongoing maintenance; and increasing and improving
infrastructure investment from all stakeholders.

In January, ASCE brought together ASCE members and infrastructure policy experts to further
focus on each of these 5 Key Solutions and several themes were identified as common problems
or needs, including the lack of a clear national infrastructure vision, the lack of decisive political
leadership, the need for a better informed public, and the need for performance-based data that
can target investments which reward good performance. While the Strategic Plan places a great
emphasis on better data collection to make more targeted and educated transportation
investments, the other common needs or problems tend to go unaddressed. 

Our nation can no longer ignore the backlog of needed improvements and maintenance to
transportation infrastructure until systems fail, which will incur even greater costs. While we
applaud the Strategic Plan’s acknowledgement of the vast problem, ASCE is concerned about
how such investments can be made without a new multi-year surface transportation bill or a new
FAA Reauthorization. Furthermore, the Strategic Plan seems to accept the lack of funding as a
given and places the focus on changing behavior and redistributing the current funding levels in
a more effective way.


ASCE commends the DOT for focusing on reducing fatalities on our nation’s transportation
systems. Highway, transit, and aviation safety is critical, with safer transportation systems
reducing the loss of life, personal injuries, and loss of economic resource. Additionally, ASCE
supports the idea that all safety initiatives must take into account elements of human factors;
pedestrians, bicyclists, and other system users; motor vehicles and their equipment; the
infrastructure; and the manner in which these components interact. Therefore, it is ASCE’s goal
to work toward zero fatalities on our nation’s transportation systems, a goal which we feel the
DOT should adopt.

ASCE is pleased to see that the strategic plan focuses on safety across all categories of the
nation’s infrastructure, including an endorsement of the High Risk Rural Roads program because
rural roads account for 57% of all traffic fatalities. However, ASCE’s primary concern about the
draft plan is the absence of solid metrics established by DOT in order to achieve reduced
fatalities and injuries. The language in the strategic plan is vague in its definition of success in
highway safety, as well as what concrete steps will be taken to achieve such a reduction. The
section lacks a focus on legislative priorities or infrastructure-based policies and instead tends to
rely on changing behaviors and collecting data that would result in a reshuffling of the highway
safety funds that currently exist. While programs targeted toward stopping distracted driving and
improving motorcycle, commercial motor vehicle, aviation, and rail safety are vital, the impact
would be greater when combined with investments to improve deteriorated infrastructure.


ASCE is concerned with the accelerated deterioration of America's infrastructure, with the
general reduction in investment for the preservation and enhancement of our quality of life, and
with deteriorating U.S. competitiveness in the world markets.

ASCE’s 2009 Report Card for America’s Infrastructure grades 15 categories of infrastructure
and for the second time our nation’s infrastructure rates a cumulative grade of “D”. While some
categories fare worse than others, all transportation categories do have one thing in common -
deferred maintenance and a history of chronic underfunding, which has led to an estimated $2.2
trillion needed to bring all 15 infrastructure categories into a state of good repair. Without
adequate investment there will be continued adverse safety and efficiency problems to the
detriment of the nation’s economy.

The DOT admits that the current level of funding is insufficient to sustain the overall conditions
of our transportation systems. However, instead of a solid policy recommendation on how to
cultivate the necessary revenue, the strategic plan looks toward developing a new set of national
system performance indicators that can drive programmatic and legislative linkages between
system performance and federal funding. Without additional federal funding and the stability
that a multi-year surface transportation bill and a new FAA reauthorization provide, it is not
feasible to increase system performance and bring the infrastructure into a state of good repair.

Furthermore, the Strategic Plan fails to define a process by which the nation can determine
whether or not infrastructure is in a state of good repair. At this time state DOTs can each have
their own definition of what constitutes a state of good repair under their jurisdiction. The U.S.
DOT should provide guidelines as to the standard that our nation’s infrastructure needs live up to
in order to be considered in a state of good repair. Without such guidelines it is difficult to
collect accurate data about the condition of the infrastructure across the nation and therefore
difficult to assess the DOT’s success in this area.


Next to safety, congestion has become the most critical challenge facing our highway system.
The DOT’s section on economic competitiveness emphasizes the importance of freight and the
impact of congestion on the nation’s economy. However the section fails to list any specific
funding recommendations beyond targeting investments toward capacity expansion on our
national freight corridors.

While taken for granted by most Americans, our infrastructure is the foundation on which the
national economy and global competitiveness depends. As the economy grows, so must these
assets. To meet the demands of our global economy, the DOT much urge a surface transportation
authorization that enhances and improves connectivity and level of service to the major
intermodal terminals, beyond just our current truck-dependant model. DOT should be working to
address the movement of freight as well as freight bottlenecks that tend to plague our current
transportation systems. By relieving freight congestion through capacity building in appropriate
corridors while making smarter, integrated transportation and land use decisions that avoid
filling that added capacity with single occupant vehicles, our nation’s ability to compete in a
global economic market can continue to grow.

Freight and passenger rail generally share the same network, and a significant potential increase
in passenger rail demand will add to freight railroad capacity challenges. Interstate commerce
remains the historic cornerstone in defining the federal role in the nation’s transportation system.
DOT should take the lead to ensure that a new authorization of transportation programs provides
for a strong federal role in freight mobility and intermodal connectors. This should include the
creation of a program funded with new dedicated revenue to provide new capacity and
operational improvements focused on securing safe, efficient movement of freight across all


Sustainability, livability and resiliency must be an integral part of improving the nation’s
infrastructure. The design, construction, and maintenance decisions we make today will be our
legacy to future generations. By applying the principles of sustainable development, our
infrastructure will continue to contribute to economic prosperity and social well being, while at
the same time protecting and enhancing the environment and our quality of life.

The Obama Administration’s shift toward livable communities contains many transformative
ideas that can improve quality of life. However, this shift should only be made in the context of a
program funded to maintain our current transportation system in a state of good repair as the
built environment supported by that system evolves. At ASCE’s recent series of Infrastructure
Roundtables, Henry J. “Hank” Hatch, the former commander of the U.S. Army Corps of
Engineers and chair of the Natural Sciences and Engineering Committee of the U.S. National
Commission for the United Nations, Educational, Scientific, and Cultural Organization, said that,
“You can satisfy the infrastructure needs in two ways: one is to provide it and the other is to
manage the demand.” Livable Communities seeks to address our infrastructure needs by creating
more choices for Americans, choices which manage the demand for infrastructure by relying
more on walking, bicycling, and transit and less on the automobile. The Strategic Plan should
clearly define the federal role of transportation policy and investment in Livable Communities
and challenge state, metro, and local governments to develop complementary land use policies.
Additionally, the Strategic Plan should include how DOT can work in conjunction with the
Department of Housing and Urban Development and the Environmental Protection Agency in
order to more properly identify completely what constitutes livable communities.

ASCE supports designing and constructing new transportation facilities for multi-use purposes
that include automobiles, trucks, transit, pedestrians, and bicycles. DOT should make this
investment and at the same time bring our transportation sector, which still heavily relies on
automobiles, into a state of good repair.


The Strategic Plan’s focus for environmental sustainability seems to encourage people to get out
of their cars in order to reduce greenhouse gas emissions. There is little to no mention of
encouraging more sustainable urban development. While the livable communities section seems
to encourage a more urban-centric development patterns, the environmental sustainability
section’s sole focus is reducing carbon emissions and water and noise pollution.

ASCE believes that sustainable development is the challenge of meeting human needs for natural
resources, industrial products, energy, food, transportation, shelter and effective waste
management while conserving and protecting environmental quality and the natural resource
base essential for future development. Sustainable development requires finding innovative ways
to achieve needed development while conserving and preserving natural resources. Therefore
ASCE supports a variety of implementation strategies including a multidisciplinary, whole
system, approach that encompasses all phases of project planning, design, construction,
operations, and decommissioning for both new and existing infrastructure.

Sustainability must be something far more inclusive than simply setting a goal to reduce
greenhouse gases without a legislative agenda in place to support this goal. Additionally, the
U.S. DOT has to seriously consider alternatives to the gas tax as a revenue generator for the
Highway Trust Fund, when pushing a strategic plan that would reduce the amount of funding
that would be available. While the plan mentions this could be a risk factor, there is no
alternative funding source mentioned as a means to make up the difference in the depleted trust


In summary, ASCE has some concerns about the U.S. DOT’s Strategic Plan for 2010 – 2015.
While the plan delves into some of the most important areas where the transportation system
needs improvement, the recommendations provided are vague, lack definitive goals, and are
marginal at best. While the Strategic Plan addresses the issue of inadequate funding in each main
goal area, there are no possible solutions suggested on how to overcome the funding dilemma.
Without adequate funding levels, many of the possible recommendations or solutions are not
feasible as a means to reach our nation’s transportation goals. That leaves us with a report full of
soft recommendations that focus on changing behavior, doing a better job of targeting existing
funding through better data collection, and merely reducing overall demand on the system.