Comments Submitted by America Walks on Retrospective Regulatory Reviews: State Safety Plan Development and Reporting

Comments Submitted by America Walks on Retrospective Regulatory Reviews: State Safety Plan Development and Reporting

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, state and local organizations working to promote walking and making communities more walkable.

This letter offers our comments regarding the Retrospective Regulatory Reviews: State Safety Plan Development and Reporting announcement. America Walks, as a non-profit organization, does not have a direct role in data collection and analysis at the state Department of Transportation (DOT) level. However, through our experience and observations, and that of our network, we believe that there can be improvements made to this process to better improve the safety and conditions for people walking throughout America.


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. According to the National Highway Traffic Safety Administration (NHTSA), pedestrian fatalities accounted for 14%of all traffic deaths in 2012. Pedestrian fatalities increased in 2010, 2011 and 2012 and remain 15% higher than the 2009 level. Officials in some of our largest cities have taken steps to address this growing concern and set pedestrian safety as the measuring stick of community traffic safety. For example, New York and San Francisco have adopted a “Vision Zero” policy, setting aggressive goals to eliminate all traffic related injuries and deaths.

Many of these communities are innovative and collaborative when addressing these issues, and we believe that both the Federal Highway Administration (FHWA) and NHSTA should continue to be the leader on pedestrian safety at the national and state levels.

Recommendations for Acton

The experts and advocates at America Walks recommend the following items be taken into consideration as ways to improve pedestrian safety. 

1. Develop and implement safety performance measures for pedestrian fatalities and injuries

America Walks has consistently campaigned for a performance requirement for years. We were encouraged that the recent transportation omnibus bill included a requirement for a pedestrian safety performance measurement. We urge both FHWA and NHSTA to make the most of this opportunity and work together to set guidelines for state and regional implementation. It should require clear reporting on progress being made on eliminating pedestrian fatalities and injuries, including implementation plans, reporting on new and effective procedures and solutions and successful approaches that could be used elsewhere.

2. Partner effectively with Metropolitan Planning Organizations (MPOs) and municipalities

Research has shown that fatality and injury rates are much higher in populated areas than along limited access highways and interstates, especially those outside of heavily populated areas. An increasing number of municipalities and MPOs are collecting and analyzing data on pedestrian safety that can be useful to DOT agencies. Federal and State DOT agencies should proactively seek partnerships with these municipalities and MPOs to better track and analyze data and solutions. Federal and state DOTs can provide much needed support in terms of financial assistance and research; in exchange, municipal engineers and planners can offer state and federal DOT on the ground insights on effective solutions. Combined efforts will ultimately lead to the same goal- solving the problem of traffic fatalities and injuries.

3. Leverage Health Departments and their data

Health departments share the DOT’s mission of saving lives and reducing injuries. They collect more information on this topic than transportation departments and have the resources available, such as hospital records, to do so in an effective manner. State DOTs can begin to work with health departments today to share data sources and collaborate to effectively analyze data to solve safety problems. DOTs can also aim to get relevant questions on hospital intake forms, such as location of injury, that can help in future analysis.

4. Triangulate with First Responders and Law Enforcement

First responders and law enforcement have the unique opportunity to objectively collect data at the crash scene. These first responders should be asked and trained to collect data that will support DOTs in their ability to understand and solve the vast pedestrian safety problems. First responders become even more critical when you consider that pedestrian collisions by definition do not require a vehicle on the pedestrian side. Many Department of Motor Vehicles do not require pedestrians to file reports and first responders can serve as one of the only source of critical information.

Ideally, police departments would work with transportation departments to identify and target the most dangerous pedestrian safety areas for education and enforcement, such as targeted intersection safety, speed reduction, distracted driving, and red-light camera running. America Walks would welcome the opportunity to work with state and local authorities to recommend programs that include the judicial branch, such as programs that replace costly fines with traffic education courses for some offense types.


More and more people are walking for daily transportation and to achieve an active lifestyle. Every person should be able to safety and comfortably walk for to meet their daily needs. Both FHWA and NHSTA are in unique positions to support collaboration between state governments, including transportation departments, other agencies and government representatives, local government and organizations, law enforcement authorities and the private sector, such as hospitals. With a concerted effort, there are specific incremental steps that can be taken that can make a critical difference to the level of traffic injuries and fatalities to pedestrians.

America Walks is ready to work with FHWA, NHSTA, and other agencies to provide policy and technical assistance on how to achieve a goal of zero pedestrian fatalities. Our website houses the latest information for professionals, advocates and citizens who are interested in building safer streets for people. For example, we recently released a set of White Papers on collaboration between transportation, health, and commerce departments, You can also find our extensive library of webinars, workshops, and discussion forums where relevant issues are explained and discussed.