SCOD, McDonnell, AASHTO, Work Zone NPRM

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Transcript SCOD, McDonnell, AASHTO, Work Zone NPRM

Supplemental Notice of
Proposed Rule Making on
Work Zone Safety and
Mobility
Update on AASHTO’s Comments
Jim McDonnell, P.E.
AASHTO
Original NPRM
• Released in Summer 2003
• State DOTs had significant concerns,
including:
– flexibility in the development of work zone
policies and procedures
– scalability of those policies and procedures to
a wide range of projects
– potential for litigation
– cost and time commitments potentially
required
AASHTO’s response to the NPRM
• AASHTO submitted significant comments
• Requested another chance to review a
draft rule, through the release of a
“supplemental” NPRM
• Supplemental rule released in mid-May
2004 for a 30-day comment period
• Ad-hoc task force that developed original
comments reviewed and commented on
the supplemental
Supplemental NPRM
• Supplemental rule accommodated a vast
majority of AASHTO’s comments
• Gave back to the states the ability to make
decisions based on their own policies and
engineering judgment
• Still a few minor points that need to be
clarified, on which AASHTO will comment
Concerns with Supplemental Rule
• Biggest concern involves project “significance”
• Determination leads to varying degrees of work
and documentation related to the work zone
impacts
• For most projects, significance is determined
based on sustained impacts that are anticipated
to be greater than that considered tolerable
based on agency policy or engineering judgment
• For Interstates, however, any work zone with
lane closures for more than 3 days would be
considered “significant”
Other Concerns
• A few remaining inconsistencies
• Requirements for specific participants in
various procedures
• A few “shall” statements
• Some confusion regarding the requirement
that “preexisting roadside safety features
be maintained” during construction
• “Cooperation” or “coordination” used
where “consultation” would be preferred
Next Steps
• Draft version of AASHTO’s response was
sent to the Chief Engineers yesterday
• AASHTO encourages all states to submit
comments, either by supporting AASHTO’s
position, expanding on AASHTO’s
comments, or submitting comments of
their own
• Responses are due Monday, June 14