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America Walks Urges DOT to Include Pedestrians in Performance Safety Measures

The Department of Transportation should propose a highway safety performance measure focused solely on the number of fatalities and injuries of people who walk, America Walks told DOT in comments submitted May 6.

“America Walks is deeply disappointed that the proposed rules acknowledged – yet ignored – requests from concerned organizations to include a specific non-motorized performance measure to reduce pedestrian deaths, currently 14 percent of all roadway fatalities!” Executive Director Scott Bricker wrote.

“As proposed, the rules would deem acceptable increases in fatalities of the most vulnerable people – those on foot – even if the overall traffic fatality numbers declined. This likely would increase the number of children, seniors, and our most vulnerable populations who are maimed and killed on our nation’s streets and highways.”

DOT in March proposed rules under Section 1203 of the Moving Ahead for Progress in the 21st Century Act (MAP-21), which calls on USDOT to establish performance measures and standards in specified Federal-aid highway program areas (23 CFR Part 490; Federal Register Number 2014-05152). Under the proposal, state transportation departments would be required to establish performance measures to carry out the Highway Safety Improvement Program (HSIP) and to assess serious injuries and fatalities per vehicle miles traveled, and the total number of serious injuries and fatalities.

The full text of the comment letter appears below:

americawalks_logo

May 6, 2014

United States Department of Transportation
1200 New Jersey Ave., SE
Washington, D.C. 20590

Attn: Federal Highway Administration
Re: Proposed Safety Performance Measures
Docket Number: FHWA-2013-0020

Comments Submitted by America Walks on Proposed MAP-2 Sec. 1203 Performance Safety Measures

America Walks is a 501(c)(3) nonprofit organization dedicated to making America a great place to walk. We lead a coalition of approximately 600 national and local organizations working to promoting walking and making communities more walkable.

This letter represents our comments regarding the U.S. Department of Transportation’s (USDOT) proposed rulemaking under Section 1203 of the Moving Ahead for Progress in the 21st Century Act (MAP-21), which calls on USDOT to establish performance measures and standards in specified Federal-aid highway program areas (23 CFR Part 490; Federal Register Number 2014-05152).

Under USDOT’s March 11, 2014, Notice of Proposed Rulemaking, USDOT would require state Departments of Transportation to establish performance measures for individual state departments of transportation (State DOT) to use to carry out the Highway Safety Improvement Program (HSIP) and to assess serious injuries and fatalities per vehicle miles traveled, and the number of serious injuries and fatalities.

America Walks is deeply disappointed that the proposed rules acknowledged – yet ignored – requests from concerned organizations to include a specific non-motorized performance measure to reduce pedestrian deaths, currently 14 percent of all roadway fatalities!

In fact, if implemented as promulgated, the rules would deem acceptable increases in fatalities of the most vulnerable people – those on foot – even if the overall traffic fatality numbers declined. This likely would increase the number of children, seniors, and our most vulnerable populations who are maimed and killed on our nation’s streets and highways. Transportation Secretary Anthony Foxx, as recently as his message upon transmitting the GROW Act to Congress April 29th, said he “won’t tolerate higher rates of bicyclist or pedestrian crashes,…” We urge USDOT to back up that pledge with specific performance measures to protect people traveling on foot and in wheelchairs.

While the proposed rules ask State governments to make “significant progress” towards achieving two of four proposed safety measures, the allowable margins of error are so great that actual increases in injury/fatality rates would be permitted. We believe this result is unacceptable.

It is impossible to follow the news in the United States today without being alarmed at the reports of people being struck in our streets. Officials in some of our largest cities, New York and San Francisco for example, have adopted a “Vision Zero” policy, setting aggressive goals to eliminate all injuries and deaths, with pedestrian safety as the measuring stick of community traffic safety. We agree with these and numerous other municipal government leaders and concerned organizations that the only acceptable figure is 0.

America Walks strongly urges the Federal Highway Administration to correct this glaring omission and to create and include as part of this rulemaking, a safety performance measure that tracks fatalities and injuries of people who walk and roll.

According to the National Highway Traffic Safety Administration (NHTSA), pedestrian fatalities accounted for 14 percent of all traffic deaths in 2012, the most recent year for which statistics are available. Pedestrian fatalities have increased for three consecutive years. If current trends remain unchanged, this year we can expect traffic crashes to be responsible for one pedestrian injury every 8 minutes and one death every 2 hours. It should be noted that communities with populations of lower socioeconomic status and communities of color are disproportionately affected by these fatality/injury rates.

While pedestrian fatalities continue to climb, so do the numbers of people who walk, according to the Centers for Disease Control and Prevention’s Vital Signs Report-“More People Walk to Better Health-August 2012”. This report documents a 6 percent increase over a five-year period of people who walk for transportation purposes only. This figure does not take include people who also walk for recreation and physical activity. There are a wealth of additional statistics on pedestrian injuries and deaths including those published by the National Highway Traffic Safety Administration and the U.S. Centers for Disease Control.

According to the proposed rules, “focusing the measures on all fatalities and all serious injuries, regardless of vehicle type, influencing behavior, or roadway characteristics, provides for a view of overall safety performance that includes all users on all public roads and limits the extent of data collection and analysis.” We respectfully disagree. When standards are measured in vehicle miles traveled (VMT), the pedestrian gets lost.

America Walks calls on USDOT and the FHWA to propose a nationally mandated goal to make walking a safe option for all Americans. This should be achieved by creating a safety performance measure focused solely on the number of fatalities and injuries of people who walk. By creating a safety measure for people who walk, USDOT will provide needed support for the most vulnerable among us, enabling everyone to have access to jobs, schools, and needed services, and improving economic opportunities and opportunities for physical activity for all Americans.

America Walks is ready to work with you however possible to provide policy and technical assistance on how to achieve a Vision Zero goal. Our http://www.walksteps.org website houses the latest information for urban planners and developers and others who are interested in building safer, complete streets. AmericaWalks.org also contains an extensive library of webinars, workshops, and discussion forums, where relevant issues are explained and discussed.

Our leaders stand ready to help develop the proper regulatory standards for our streets. America Walks calls on you to help keep the people safe and healthy by adopting a pedestrian performance safety standard as part of the final rules. Thank you for considering our comments. If we can assist you in any way, please contact me at SBricker@americawalks.org or phone 503 757-8342.

Sincerely,

Scott Bricker
Executive Director
America Walks