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September 17, 2010 - ASCE Comments - National Tunnel Inspection Standards

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September 17, 2010

Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, D.C. 20590-0001

RE: National Tunnel Inspection Standards

The American Society of Civil Engineers1 (ASCE) is pleased to submit these
comments to the Federal Highway Administration in overall support of the agency’s
proposal to create National Tunnel Inspection Standards (NTIS), 75 Fed. Reg. 42643
(July 22, 2010). Our support is qualified by exceptions noted below.

The agency proposes to establish minimum national tunnel inspection standards
for all tunnels built or renovated with federal funds provided under the Federal-Aid
Highway Act. The tunnel standards would resemble the most recent National Bridge
Inspection Standards (NBIS) adopted by the FHWA and administered by the states, 69
Fed. Reg. 74419 (2004). The proposed NTIS would replace the FHWA’s non-binding
guidelines for tunnel inspections that were issued in 2003. 

A. Tunnel Defined

ASCE agrees with the decision to define “tunnel” to conform to the definition
adopted by the American Association of State Highway Transportation Officials

The AASHTO T-20 Technical Committee for Tunnels defines tunnels as
enclosed roadways with vehicle access that is restricted to portals
regardless of type of structure or method of construction. Road tunnels
following this definition exclude [an] enclosed roadway created by airrights
structures such as highway bridges, railroad bridges or other
bridges. … [R]oad tunnels also require special considerations[,] including
lighting, ventilation, fire protection systems, and emergency egress

This proposed definition generally adopts our recommendation to the agency in
response to the advanced notice of proposed rulemaking, ASCE Comments to the
Federal Highway Administration on National Tunnel Inspection Standards (February

Adoption of the T-20 definition would result in regular attention to all parts of a
tunnel such as fire protection systems and auxiliary structures. This approach is
important in order to ensure that all critical engineered systems in a tunnel are

B. Tunnel Inspections

ASCE supports the requirement that tunnels be inspected at least once every
two years.

Although ASCE recommended a more flexible approach to the scheduling of
tunnel inspections based on the age and complexity of the tunnel systems in its
response to the advanced notice of proposed rulemaking in 2008, we recognize that the
requirement to inspect tunnels at least every 24 months matches the inspection
frequency for bridges under the NBIS, 23 C.F.R. § 650.311. A similar schedule for the
nation’s tunnels is sensible and maintains consistency between the bridge and tunnel
programs, which assess complementary engineered systems on the nation’s highways
and which require a focused attention to avert potential catastrophic failures.

C. Qualifications of Personnel

ASCE supports strengthening the requirement in section 650.509 of the
proposed rule in order to protect public safety.  

The proposed rule would require a licensed Professional Engineer (PE) or a
person with at least 10 years’ experience in tunnel inspections to become a “program
manager” under the NTIS. This would allow persons without an engineering degree to
substitute 10 years’ experience in tunnel inspections. The program manager would be
defined by the NTIS as “[t]he individual in charge of the inspection program who has
been assigned or delegated the duties and responsibilities for tunnel inspection,
reporting, and inventory.” 75 Fed. Reg. at 42657.

“The FHWA believes that, for the tunnel inspection Program Manager,
experience with inspection of transportation structures is as valuable as professional
registration.” Id. at 42652.2

ASCE strongly disagrees with this statement. Every federal, state, or local
government agency ought to require licensure as Professional Engineers (PEs) of state
employees (1) who are trained as civil engineers and (2) who are responsible for
supervising or designing the engineering of public projects and programs. The
licensure requirement must satisfy the legal requirements of the jurisdiction within which
the project is to be constructed or regulated.

The program manager under the NTIS would be in overall charge of a state or
federal tunnel inspection program. As described in the proposed rule, the position
would assume total responsibility for the implementation of the NTIS and its application
to highly complex engineered structures. No amount of experience with intricate
infrastructure systems alone can replace the detailed technical knowledge acquired by
academically trained engineers and licensed PEs.

The engineer who has responsible charge of a public project should be a
licensed Professional Engineer in order to ensure the public health, safety, welfare, and
the protection of the environment. ASCE believes the selection and appointment of
qualified professional engineers to government positions requiring professional
engineering knowledge to conduct operational and management decisions for
engineered systems is essential to the protection of public health and safety. Such
positions include the oversight of design and construction of public works projects,
leaders and managers of civil-engineering-related government agencies, and other
positions involving similar responsibilities for the safety, health and welfare of the public.

Finally, in waiving the PE requirement, nothing in the phrase “or have 10 years
tunnel inspection experience” even hints at the need for a degree in a technical
discipline—or any academic credential at all. This lack of a minimum level of
professional and scholarly training for program managers is a serious deficiency in the
July 22 proposal. At the very least, the standard for personnel qualifications for
program managers in section 650.509 should be revised to clearly require a program
manager to possess (1) an undergraduate degree in civil or mechanical engineering,
with professional expertise and experience in structural and geotechnical disciplines
and (2) a PE from the state in which the manager is working.

D. Tunnel Inventory

ASCE supports the proposal to require each federal agency or state to complete
an inventory of tunnels in their jurisdictions within 30 days of the adoption of a
final rule.

An accurate inventory is essential to the success of a national inspection
program. In addition to name, location, age, length and other basic statistics, the
inventory would include information on portals, geometric ground conditions, lane
clearances, and other geodata. The standard should be amended to include a
complete description of the mechanical systems. These standards should ensure each
tunnel and tunnel system receive timely inspections and necessary repairs or

Respectfully submitted,