MAP-21 identifies national transportation goals and requires the FHWA to promulgate rules to establish performance measures in specified Federal-aid highway program areas. The proposed rule (National Performance Management Measures; Assessing Pavement Condition for the National Highway Performance Program and Bridge Condition for the National Highway Performance Program) published January 5, 2015, was opened for industry comments.

AgileAssets appreciates the opportunity to comment on these proposed rules, and to support a transition to the use of performance measures for long‐term management of pavement and bridge assets, as outlined in the MAP‐21 legislation. Based on our long history of supporting and consulting with agencies for their pavement and bridge management, we have three main comments as follows:

Managing to legislated minimums for pavement and bridges in Poor condition may encourage agencies to return to a “Worst First” Policy

Although we understand the need to put limits on the quantity of assets in Poor condition, managing purely to this statistic has been shown to be counterproductive in terms of maximizing the overall condition of the network over the long‐term. We would strongly propose that agencies continue to be encouraged to keep their roads and bridges in a generally
good condition (using currently established agency performance indices) rather than merely keeping them out of the Poor category.

Challenges of managing pavement ‘management sections’ as opposed to 1/10th-mile sections

In our experience, agencies manage their pavements using ‘management sections’ that are typically longer than a 1/10th mile. This is with good reason since this generates reasonable work plans that do not require a great deal of post-processing to develop realistic pavement projects. Even those performance models that project a distribution of condition (e.g., % of length with IRI > than a certain threshold, % length with rutting exceeding a given value, etc.) do not project which locations within the management section will exceed the prescribed thresholds – rather, only a percentage of the section as a whole. Since the required statistics are based on the combination of locations that exceed the thresholds, the only way to utilize the projected conditions requires the states to assume that all “poor” subsections of the longer management sections fall within the same sub-section of the management section. This assumption is overly conservative and may lead to the target setting and reporting to be erroneous. For target setting and reporting of projected network condition, we recommend statistics that are more amenable to projections on a project or management section basis. This may be best done by reporting current condition and setting target conditions based on each of the identified condition measures individually, rather than a combined “2 out of 3” approach.

Effort of modeling, prediction, and reporting of additional distresses

Historically, although agencies have been reporting using HPMS, they have not necessarily been using these (exactly as defined for MAP‐21 reporting) distresses and metrics to manage and
model their pavements in their pavement management systems. We predict that even if agencies continue to use their historical distress and performance measure calculations in their
management systems, and also continue to use management sections, agencies will now want/need to also model and predict additional distresses to match those being reported. This
will again result in additional effort and expense being required to fully embrace and adopt the legislation.

In summary, we firmly support the transition to a Performance and Asset Management approach for managing the transportation network as envisioned in MAP 21. The principals of Asset Management do promote a strategic and long‐term view.

We are concerned that the proposed MAP 21 Pavement and Bridge rules, as written, may in fact force agencies to make poor, short‐term project and program decisions in an attempt to satisfy imposed thresholds, while abandoning optimized work plans generated by their pavement and bridge management systems that improve overall network health over time while providing sustainable performance.

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