Benjamin R. Frevert - Comments

With regard to the concern about ensuring that ITS investments made today to comply with the rule are sustainable over the long term, this seems to be the wrong question. Investments in ITS are analogous to purchasing a personal computer. By the time you complete your research on features and functionality, make a purchase, power up and connect to the Internet, your new computer is at least a bit out of date. This doesn't mean purchasing a computer is a bad investment. I think rather that the question we should be asking here is, "How do we determine which investments in ITS can be regarded as cost effective given that they are going to become obsolete in short order relative to more conventional transportation investments?" Traffic monitoring cameras and systems provide a good example. While they can provide operations personnel with incredibly valuable information that helps them manage congestion, video processing and transmission technologies are evolving at such a rapid pace that systems interoperability must be closely monitored when expanding video systems. This simply means we need to do a good job with the engineering of these systems, not that we should discourage their deployment.