AASHTO Comments on Proposed Highway Safety Plan Changes

The American Association of State Highway and Transportation Officials recently submitted comments on a notice of proposed rulemaking or NPRM regarding potential changes to the Highway Safety Improvement Program or HSIP overseen by the Federal Highway Administration.

[Above photo by AASHTO]

While AASHTO said its supports applying “safe system” concepts to the HSIP along with other programs and projects overseen by FHWA – as well as considering all road users and equity issues as related to those initiatives – the organization expressed “significant concerns” regarding the proposed regulatory changes to HSIP requirements for states and their implementation.

Those concerns include:

  1. FHWA’s statutory authority to implement new requirements, such as system-wide safety risk assessments and approval by FHWA division administrators of HSIP processes.
  2. The clarity of proposed requirements, including aspects of definitions, data elements, and analysis methods, which severely limits the specific comments and suggestions states are able to provide within the NPRM comment period. In addition, if clarification is not provided until FHWA issues guidance after a final rule is published, states will not have had a chance to provide on how the missing details will affect their safety programs.
  3. The underestimation of cost and burden impacts, which will further limit the ability of state DOTs to deliver safety projects as they focus significantly more funds and staff on administrative activities.
  4. Implementation challenges, such as availability of data and related coordination with other state DOT and non-state DOT programs within the HSIP timeline; technical challenges related to evaluations and assessments; and varying needs among diverse state funding levels and roadway networks.

“We urge FHWA to significantly revise the proposed HSIP requirements to more directly reflect the congressional intent of the safety-focused provisions of the Infrastructure Investment and Jobs Act; scale requirements to the program size so that states are not forced to significantly limit their safety improvement projects to meet administrative requirements; and provide additional clarity with an opportunity for states to provide constructive input,” AASHTO said in its letter.

“The NPRM presents a number of proposed requirements that will present significant challenges to states as they plan, implement, evaluate, and report on their state HSIPs – and those challenges are expected to be even greater once additional details are established,” the organization added.

“We encourage FHWA to discuss with states and AASHTO the details of implementing existing HSIP requirements in a practical sense,” AASHTO pointed out.

That includes addressing the “details of implementing these proposed requirements before finalizing any related regulations to ensure a full understanding of the issues and to jointly identify alternatives that will serve the same objectives while creating less additional burden to both the states and FHWA,” the group noted.

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