Eric Peter Fields - Comments

Document ID: FHWA-2008-0038-0005
Document Type: Public Submission
Agency: Federal Highway Administration
Received Date: December 08 2008, at 12:56 PM Eastern Standard Time
Date Posted: December 9 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: November 18 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: February 17 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 807cef31
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This is comment on Rule

National Tunnel Inspection Standards

View Comment

Under the NBIS guidelines, a "tunnel" is not considered a bridge per 23 CFR 650 and Question 303-1 (http://www.fhwa.dot.gov/bridge/nbis/index.htm). There is no detailed definition of tunnel leading to a wide ranging determination of the difference between a tunnel and a bridge for regulatory purposes. In the proposed rulemaking, only Federal Aid Highway "tunnels" will be governed by the rulemaking meaning that the highway use will be within the tunnel structure. If this definition is final, in the case where you have a grade separation in a structure called a tunnel with the public highway supported by the tunnel, that structure will not be regulated as a highway bridge under the original NBIS or as a highway tunnel under the proposed NTIS. The regulation will exempt many of these structures from inspection. I would recommend that regulatory authority be extended to "tunnels" that enclose or support a public highway use regardless of the entity.