Idaho Association of County Engineers and Road Supervisors - Comments

I am in support the provisions in MAP-21 concerning CEs for projects in the right-of-way and projects receiving limited federal funds. Please note: 1) The original MAP-21 wording adequately defines the use of these CEs. 2) The proposed rulemaking limits the original intent of MAP-21. 3) The attempt to redefine the operational right-of-way is restrictive and limits the intent of MAP-21. 4) FHWA should use the language in MAP-21 to define operational right-of-way. 5) The MAP-21 language concerning projects receiving limited federal funds is clear and concise. Do not add the qualification of "projects that do not require Administrative actions other than funding."