Bob Wagar - Comments

Follow up to 0654. This NPA will extend or remove compliance dates, but does nothing to reduce STANDARDS. It is clear from wording in NPA that elimination of compliance dates does not eliminate the regulatory requirement to comply with Standards. FHWA needs to review all STANDARDS and modify many to either Guidance or Options. I would recommend that FHWA put out another Notice asking for input and comments on all STANDARDS that exist in the 2009 Edition. Specific for Table 1-2 Disagree with requirements for additional Horizontal Alignment Warning Signs in Table 2C-5. These requirements place huge burden on state and local agencies to provide additional signs. In many cases these signs will have little to no value. Request FHWA reconsider this requirement and at minimum delete compliance date of December 31, 2019. As stated in 0654, if FHWA has policy of deleting items from Table 1-2 for dates that have passed, there is no reason to have 6D.03, 6E.02, or 7D.04 in table. By the time FHWA can act on this NPA those dates will have passed. Retroreflective strips on Crossbuck signs and supports. I question if this is worthy of having compliance date. Deadline for having these has already passed (Jan. 17, 2011) and I have not seen any of these installed. I would question if the safety benifit of these proposed strips justifies there requirement. I am strongly opposed to requirement for using STOP or YIELD signs at all passive grade crossing. When congress set out requirements for these signs they limited to locations with more than one train a day. I beleive the reason for this was to exclude track locations with very low train volumes. I understand there are 180,000 passive tracks in the US. Placing STOP or YIELD at all crossings will be very expensive and will violate one of basic requirements of sign to command respect from drivers. There are many problems with this requirement and much more research should be done before requiring