Comments on U.S. Department of Transportation Draft Strategic Plan

American Traffic Safety Services Association

The American Traffic Safety Services Association (ATSSA) commends the Department of Transportation's continued focus on safety in all of the modal administrations. As the draft strategic plan notes, the U.S. has made great progress in reducing fatalities on America's roadways; however, much more can be done to continue to work toward zero deaths on our roads. The plan emphasizes five areas of focus for roadway safety, including infrastructure safety.

ATSSA agrees that engineering/infrastructure safety applications yield a tremendous benefit for reducing fatalities and serious injuries. In the most recent transportation authorization, MAP-21, Congress and the Administration agreed, with the enactment of a continued and expanded Highway Safety Improvement Program (HSIP). We believe that it is more than a coincidence that the increase of funding for the HSIP strongly correlates with the decrease in fatalities over the past five to six years. We understand that a straight slope decrease is likely an anomaly, and that future trends will most likely be a “jagged line” (picture a stock market chart); nevertheless, our country is definitely moving in the right direction!

Part III, Safety, correctly places initial focus on roadway safety, as 90.4% of fatalities occur in this mode. In recognition of the tragic number of fatalities on our roadways, ATSSA was the first national association to follow eight pioneering state departments of transportation and adopt a goal of Toward Zero Deaths (TZD). At this juncture, through the positive work done through the American Association of State Highway and Transportation Officials (AASHTO), over half the states have adopted some form of TZD. It would seem appropriate for the U.S. Department of Transportation to also do so and to assume a leadership role in this national effort.

In addressing the recent decline in motor vehicle fatalities on p. 12, the fourth bullet, or “v” point, focuses on increased data analysis and targeting of resources. ATSSA believes that more recognition at this point should be given to state DOT deployment of infrastructure safety countermeasures on a systemic basis. Witness the miles of median cable barrier installed on many interstate highways with a 95+% success rate in reducing crossover fatalities. The draft Strategic Plan also highlights a "system-wide implementation of proven safety countermeasures, traffic calming measures such as roundabouts and innovative intersection design" (page 13).

States should also look to the soon-to-be-released FHWA report on rural road safety for examples of projects around the country that yield positive returns on investment. To further enhance safety, the Department of Transportation should also encourage states to bring all stakeholders to the table, including the roadway safety infrastructure industry, when they craft their updated strategic highway safety plans. This will further bolster a state's efforts to expand roadway safety and even further reduce fatalities and serious injuries.

The draft plan also calls for upgrades to state and local data systems for safety. ATSSA agrees that data collection needs to continue to be a priority for state and local entities in order to best determine the countermeasures that are appropriate for their area and safety challenges.

ATSSA agrees with the draft plan's focus on rural road safety as well (pages 13-14). Because of the higher rate of fatalities on these roads, rural road safety applications must be a focus for state and local entities. However, in order to do so, states should also be coordinating and collaborating with local and county governments and the roadway infrastructure safety industry in order to receive a holistic view of rural roadway safety.

On page 14, the draft plan discusses safety for pedestrians and bicyclists as well as all road users. ATSSA agrees that taking all roadway users into account when designing roads can have a positive safety benefit. In addition to the list in the draft plan, other countermeasures include bike lanes, signs and pavement markings with high levels of retroreflectivity, channelizers and crosswalks, among others. In the reference to complete streets on p. 14, DOT should consider the development of “low tech” guidebooks for “retrofitting” for complete streets.

In order to enhance older driver safety, the DOT draft plan should also commit the Department to updating the FHWA Highway Design Handbook for Older Drivers and Pedestrians which was last updated in 2001. MAP-21 now clarifies that projects associated with the Handbook are eligible within the Highway Safety Improvement Program. States should put a focus on low cost infrastructure improvements that can make the roadways safer for not only all drivers, but older drivers in particular. This is a way to allow folks who do not have access to alternative transportation to still drive for a longer period of time in a safer environment.

Roadway Safety Audits/Assessments have proven to be a valuable tool for communities to use when assessing their safety needs. In addition, someorganizations are focusing these audits/assessments on teens throughout the country with great success. The DOT draft plan mentions developing training programs for children, among other groups; however, the DOT should consider partnering with organizations that are already working on these programs, such as the National Organizations for Youth Safety (NOYS), ATSSA, and the Roadway Safety Foundation which together have developed a road safety assessment program for teens called the TeenRSA Program. These organizations have dedicated their own funds to develop a pilot program as well as instructor and participant guides. DOT could play a crucial funding role in taking this program nationwide.

One roadway safety strategy that seemed to be absent from the plan was a focus on work zone safety. Work zone safety is a key component of reducing roadway fatalities for both the motorist and the roadway worker. Prior to the enactment of SAFETEA-LU in 2005, on average, more than 1,000 people a year were killed in work zones in the United States. Due to the tremendous progress made from the Work Zone Safety Grant, over the past few years, that number has been dramatically reduced. In 2010, there were 576 fatalities in work zones. While that number is animpressive improvement, there is still more to do. ATSSA feels it is important to include a focus on work zone safety in the DOT Strategic Plan to continue to drive down these fatalities.

The draft plan repeats an often used assumption that researchers estimate that driver behavior causes or contributes to 90% of crashes; ATSSA feels that the cost of driver error should not be death. Consequently, we must continuously work to make our roadways safer.

While we focus on making the roadway safer, ATSSA agrees that safe driving should be promoted. From this perspective, DOT should also play a key leadership role in promoting a safe driving culture among all road users. Several organizations, notably the AAA Foundation, have undertaken significant early steps in this area. DOT could help to promote the safety culture agenda nationwide. ATSSA is willing to work with the DOT to identify ways that infrastructure safety improvements can contribute to a safety culture and has already taken initial steps in this area.

ATSSA understands that the DOT strategic plan was organized into several distinct sections and anticipates that given the DOT’s agency-wide commitment to safety that the safety concept will be included in other sections even if not specifically mentioned. In regards to Part VI, Livable Communities, ATSSA urges DOT to consider the promotion of Pedestrian Travel Safety Assessments based on FHWA’s successful Roadway Safety Assessment program.

In the area of Access for Persons with Disabilities (p. 58 et. al.), ATSSA was the very first organization to sponsor special demonstration workshops for devices to enhance the accessibility of work zone pedestrian walkways for persons with disabilities. ATSSA partnered with FHWA, the U.S. Access Board, and several organizations representing persons with disabilities to bring them together with the manufacturers of work zone barriers and devices to get actual “instant feedback” from the users to critique and evaluate these devices. The result has been the development and/or modification of devices that provide greater pedestrian accessibility in work zones for those with disabilities. ATSSA would be pleased to support any further efforts by DOT in this area.

ATSSA applauds the DOT for its continued focus on safety and its commitment to further reduce fatalities and serious injuries nationwide. By working with all partners and stakeholders, this vision of roadway safety in America canbecome a reality.