511 Coalition - Comments

Members of the 511 Coalition submit this reply to NPRM 23 CRF Part 511, Real- Time System Management Information Program. The 511 Coalition is a partnership between AASHTO, the American Public Transportation Association (APTA), the Intelligent Transportation Society of America (ITS America) and the United States Department of Transportation (U.S. DOT), and 511 deployers. The Coalition members wish to thank the FHWA for the opportunity to provide comments on the NPRM, and how implementation of the Real-Time System Management Information Program might affect Coalition members. At a high level, it is the belief of the Coalition that the NPRM is well meaning, and ultimately the implementation of such a program would be beneficial to many DOTs and other agencies, as well as members of the traveling public. The idea of being able to travel from one region or state to another and have a seamless network of information available via a single resource (your own state’s ATIS system), would ease much of the burden of “hunting around” every time a user requests information from a new system. The Coalition believes that in theory having a common database or repository of data that can be tapped by DOTs and ATIS providers would be highly valuable; and that requiring ATIS deployers to provide or make their information available to this database, and making sure that any deployer wishing to could access this database for integration into their own data service, would support the goal of populating this common repository. However, we believe at this time, that the requirements suggested by the NPRM will be, in many cases, more than most DOTs will be able to accommodate at this time and should be more locally nuanced and responsive to specific user needs. Even in the case of states where there are existing traveler information services (511 systems and websites), not all roadways are covered in a manner that would meet the NPRM requirements for timely data gathering. Those who do not have ATIS in place would be further burdened by creating systems with requirements beyond their own needs such as coverage of rural areas and weather information in parts of their states where it may not be available, and all in a relatively short time-frame from inception to implementation. Furthermore, monitoring performance of new roadway sensors, traffic data collection systems, data provided by third parties, and roadway weather information systems represents another unfunded level of effort for state and local agencies.