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Performance management comments to FHWA

May 23rd, 2014

The FHWA solicited comments regarding National Performance Management Measures. Here are our comments.

The following are comments from the California Association of Bicycling Organizations (cabobike.org) regarding the DOT/FHWA Federal Register, 23 CFR Part 490, National Performance Management Measures; Highway Safety Improvement Program. Docket Number FHWA-2013-0020

1. The codes of all states should adopt the provisions in the Uniform Vehicle Code concerning bicycles, particularly the provisions defining bicycles as vehicles and bicyclists as drivers of vehicles (or at least as having the same rights and duties of drivers of vehicles as far as the rules of the road are concerned), as recommended by the 1975 report of the NCUTLO Panel on Bicycle Laws.

2. The Federal government and the codes of all states should recognize shared use paths as highways.

3. The right of bicyclists to use all public streets and highways, exclusive of certain motorways for which non-motorized alternates exist, should be confirmed.

4. Mileposts should be placed on shared use paths.

5. Bicycle mode share, bicycle counts and bicycle-miles traveled on both highways and shared use paths should be included in the Highway Performance Monitoring System.

6. Bicycle collisions on highways and shared use paths should be included in the NHTSA and FHWA traffic safety state motor vehicle crash databases.

7. Collisions and casualties involving bicyclists should include walkways and shared use paths.

8. Traffic collision report forms need to include:
a. Bicycles as a vehicle type;
b. Check boxes for location of bicycle just before impact: center of traffic lane, right-
hand edge of traffic lane, shoulder, bike lane, crosswalk, walkway and shared use path;
c. Entry for width of traffic lane, bike lane, shoulder, walkway or shared use path;
d. Entry for whether the bicycle was carrying a passenger; and
e. Milepost on highway or shared use path.

9. The National Committee on Uniform Traffic Laws and Ordinances should be resurrected with partial or full funding from USDOT.

Finally, bicycle traffic safety needs to be treated as seriously as motor vehicle safety.

Thank you for consideration of our comments.

Jim Baross
CABO President

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