FHWA Notice of Proposed Rulemaking
On November 24, 2020, the Federal Highway Administration (FHWA) issued a notice and request for comment regarding Design Standards for Highways (Docket No. FHWA-2019-0030). The American Concrete Pavement Association (ACPA) reviewed the proposal and provided detailed industry comments.
The proposed rule would allow States to develop design standards for resurfacing, restoration and rehabilitation projects—known as RRR—for freeways, including those on the interstate system.
Summary: ACPA’s Response
Submitted by Leif Wathne, Executive Vice-President-ACPA
December 24, 2020:
- Although ACPA supports changes in regulations that would allow State DOTs to develop RRR freeway projects using a performance-based, flexible approach, we feel it is critically important that any such approach prioritize and ensure cost effectiveness together with safety and regulatory relief
- ACPA supports the view expressed by AASHTO more than 60 years ago: ‘All possible and proper measures be taken to ensure taxpayers of this country that they are receiving the full value of every highway dollar spent‘ (1)
- The concrete pavement industry contends this applies in the resurfacing, restoration, and rehabilitation (RRR) arena, as well.
- One important way that FHWA can ensure cost effectiveness in this context is to modify the proposed language in section 625.3 (a) (1) (iii) from: “Cost savings by utilizing flexibility that exists in current design guidance and regulations; and…” to “Life-cycle cost savings by utilizing flexibility that exists in current design guidance and regulations; and…” (emphasis added)
The document adds that it’s ACPA’s posture:
Use of life-cycle cost analysis (LCCA) is the only plausible way to ensure ‘economy of maintenance’ as required by the Standard in 23 USC 109(a)(1) and the Policy in 23 CFR 625.2(a)(1).
Without an explicit focus on life-cycle costs (or, as articulated by Congress in TEA-21, a process for evaluating the total economic worth of a usable project segment by analyzing initial costs and discounted future costs, such as maintenance, user, reconstruction, rehabilitation, restoring, and resurfacing costs, over the life of the project segment), the concept of ‘economy of maintenance’ has no meaning (2).
Regarding FHWA’s proposed changes in 23 CFR 625.4, the comments affirm ACPA’s support of those proposed changes to incorporate by reference the latest versions of design standards and standard specifications that have been previously adopted. For the complete ACPA document, please go to: www.acpa.org/wp-content/uploads/2019/02/ACPA-2020-FHWA-RRR-NRPM-122420.pdf. For FHWA’s proposed rule, as posted in November, please go to: www.acpa.org/wp-content/uploads/2019/02/FHWA-NPRM-2020-25679.pdf
(1). “An Informational Guide on Project Procedures,” American Association of State Highway Officials (AASHO), Nov. 26, 1960
(2). Transportation Equity Act for the 21st Century, Public Law 105-178, Section 1305(c)
FHWA Hosts 2nd
“Pavement Resilience Peer Exchange”
This two-day “Pavement Resilience Peer Exchange” was held mid-December, 2020 and the 2nd of 2 FHWA-sponsored pavement resilience peer exchanges (1st was October 7-8, 2020). Representing the concrete pavement industry were: Jim Mack, Director-Market Development-CEMEX* and ACPA Past-Chairman (2019); John Adam, Program Manager-CP Tech Center; and Eric Ferrebee, Director–Technical Services-ACPA; and Brian Killingsworth, Executive Vice President-NRMCA.
Welcome:
Kurt Smith, APTech*
Heather Dylla, FHWA
Explained that this 2nd peer exchange was aimed at defining more resilient pavements to help meet sustainability requirements
Sessions:
“Asset Management and Resiliency” by
Steve Gaj, FHWA—focussed mainly on the TAMP and AM rule. He noted the work on the next TAMPS is due in the summer of 2022
“Extreme Events and Effects on Pavements” moderated by
Steve Muench, University of Washington addressed by
Dr. Bart Nijssen, University of Washington
reminded the group that models are showing climate is changing, but cautioned that climate change is not the only “stressor” that affect planning for extreme events:
• Population increase
• Lack of funding
• Other variables
“Transportation Impacts of High-Tide Coastal Flooding” presented by
Dave Kriebel, US Naval Academy presented
• Described the impacts on streets and roads
• Provided some good ways to estimate the number of flood events
• Provided some good mitigation strategies
• Emphasized the importance of making design changes
Breakout sessions
Aimed at identifying issues and challenges among state roadbuilding agencies represented at the meeting, including those from Illinois, Wyoming, Virginia, Hawaii, and Maryland. Jim Mack commented, “We think we have a good pavement system to address many resilient issues. Concrete pavements are inherently stiff and reliable for the long term. We are educating more people about the versatile solutions we have, including overlays, full-depth pavement reclamation with cement, etc., and as we do, we are looking at all potential resiliency needs from flooding, fires, etc. We’re trying to get research done – and recognition that both immediate and secondary impacts, while at the same time looking at climate change overall. One example is with CO2 reduction, where we are looking for quicker adoption of technologies such as portland lime cements (PLC), which are reducing our carbon footprint. We need the DOTs to be receptive to those technologies.”
Breakout 2 led by
Steve Muench and Tom Van Dam, NCE*
Officials from Alaska, Arizona, Florida, Iowa, Missouri, New Mexico, North Carolina, South Carolina, Texas, Virginia described challenges they are facing. Topics ranged from permafrost melting in Alaska to the severity and frequency of major flood events, which was a common theme among many of the state agencies.
John Adam
Said there is a need for increased communication so we can “restore” operations. He commented, “Essentially, when can we reopen and what are the options, so the procedures are in place to respond rapidly. There’s a need to be proactive so don’t have to make up procedures on the fly.”
DAY 2
“Welcome and Recap of Day 1” by
Tom Van Dam and Steve Muench
Technical presentations:
• “Introducing Climate Resiliency into Pavement Management” framework by
Jo Sias, University of New Hampshire and
Jayne Knott, JFK Environmental Services
• “Resiliency of Major Freeway Sections in the Houston Area” by
Andrew Wimsatt, Texas A&M Transportation Institute
Breakout Session:
• “Role of Pavements” led by
Steve Muench and Tom Van Dam
• Small group exercises facilitated by
Prashant Ram, APTech
• “Breakout Group Reports” session led by
Steve Muench and Tom Van Dam
• “Summary and Wrap-Up” by
Steve Muench and Tom Van Dam
• “FHWA Resources and Initiatives” by
Elizabeth Habic, FHWA.
Throughout the meeting, there were concerns expressed about:
Thin, flexible pavements and their performance in disaster situations—there’s a need to communicate more and ensure resilience is factored into design.
Predictive modeling—Much discussion, but it’s important not to rely too heavily on models when there are improvements that can be made by working with key DOT officials on implementing existing technologies and practices.
Funding—a key consideration that needs to be addressed as flooding responses and other disaster recovery methods become more important
Please see related ACPA article:
ACPA peer exchange 2 article: “FHWA Hosts Second Pavement Resilience Peer Exchange”: https://www.acpa.org/industry-news/26946/
ACPA peer exchange 1 article: “FHWA Presents Pavement Resilience Peer Exchange”: https://www.acpa.org/news/24682-2/
Please see ISCP peer-exchange-related FHWA articles:
“IGGA & CP Tech Center Partner on FHWA’s EDC-4 Pavement Preservation “HOW” Peer-Exchange Project”—10 regional FHWA Peer exchanges between September 2018 and May 2019: www.concretepavements.org/2020/09/15/igga-cp-tech-center-partner-on-pavement-preservation-project/
“FHWA TFG Discusses New Concrete Pavement Technologies, Pooled Fund Update, PEMs, Fly Ash, & Concrete Overlays”: www.concretepavements.org/2020/10/09/fhwa-tfg-discusses-new-concrete-pavement-technologies-pooled-fund-update-pems-fly-ash-concrete-overlays/