An initial “peer review” by a leading private nonprofit research body faults research conducted by the Dept. of Transportation to inform its Comprehensive Truck Size & Weight Limits (CTSW) study as amounting overall to being “a missed opportunity.”
This first of two peer reviews reports— which were requested by DOT to critique the agency’s CTSW study-- has been released by a committee of the National Research Council’s Transportation Research Board (TRB).
As part of the DOT size-and-weight study, mandated by the MAP-21 surface-transportation bill, the Federal Highway Administration (FHWA) completed a series of “desk scans” that describe research completed, methods and techniques employed in other research initiatives and the resulting findings.
FHWA said the desk scans were “focused on completed work in areas related to the study to inform the project plans and technical analysis.”
The desk scans cover the study areas of “Bridge, Compliance, Modal Shift, Pavement and Safety.”
While the TRB peer-review committee found that several of the desk scans “provide useful documentation of resources that will be valuable in the CTSW study,” it also stated flatly that “as a whole, the scans represent a missed opportunity.”
Per TRB, there are two elements that are “incomplete in most of the desk scans” that would have been most useful in conducting the CTSW study:
- “Identification of alternative methods, tools, and data for estimating impacts of changes in size and weight regulations that might have been applicable in the 2014 study or in future USDOT evaluations of these regulations”
- “Syntheses of past studies that indicate reasonable ranges of values for impact estimates and allow comparison of the 2014 study’s estimates with those of past studies”
But wait, there’s more. The review committee also found that “in most cases, the desk scans do not appear to have been instrumental in developing the study team’s analysis plans, but rather to have been prepared after the plans had been decided on.
“The desk scans primarily contain lists of studies and other information sources with capsule summaries,” the report notes. “The basis for selection of sources is sometimes unclear, and as the documents acknowledge, many of the listed sources are not relevant to the CTSW study.”
In addition, the committee blasted the shortsightedness of the desk scans: “References to the primary research literature are nearly absent in most of the desk scans, so any innovative analysis methods appearing there would have been overlooked.”
TRB also observed that “if an ongoing federal program of monitoring and evaluation of trucking regulations, as recommended by the 2002 TRB truck size and weight study (TRB 2002, 6), had been in place, the priorities and analysis alternatives for the 2014 study could have been established at the outset.”
The committee recommended that each desk scan should include an “an analytical synthesis of quantitative results of past evaluations of size and weight regulations.”
As TRB sees it, such syntheses would serve two critical functions:
- “Set priorities for the use of resources in the DOT study by establishing what is already known about impacts of changes in size and weight regulation and by indicating which uncertainties critically hinder decision-making on the regulations”
- “Provide context for the impact estimates of the present study by affording comparisons with estimates of past studies by DOT, TRB, the States, and others. If DOT’s estimates differ from those of past studies, the sources of the differences will need to be explained whether they arise from differences in the environment (e.g., traffic volumes or infrastructure conditions), in the policy options analyzed, or in data and analysis methods”
TRB stated that the results of these syntheses “would inform the ability to reach firm conclusions about the consequences of changes in truck size and weight limits on safety, efficiency, infrastructure, and the environment.”
Not surprisingly, the shortcomings in the study’s methodology pointed up by the TRB review serve up red meat for highway-safety interest groups that oppose increases to federal truck size and truck weight limits— especially any such changes that could be part of the next surface- transportation reauthorization bill.
Leading the charge is the Truck Safety Coalition (TSC), a partnership between the Citizens for Reliable and Safe Highways (CRASH) Foundation and Parents Against Tired Truckers (PATT), which this morning hosted a press conference on Capitol Hill with other interest groups and Representative Jim McGovern (D-MA) to state their opposition to changing truck size/weight rules.
“Concerns about a dangerous and deadly policy change in federal law are heightened because DOT is currently conducting a study on truck size and weights which has significant flaws and potential biases,” stated TSC in a news release.
TSC added that the TRB peer review “verified many of the concerns and criticisms by [safety-interest groups] about the flawed methodology being used and the short time frame for completing the study. The report concluded that these two factors would likely yield inaccurate study results.”
Rep. McGovern stated that he has “serious concerns about the [DOT] study… If DOT does not include the most common configurations of big trucks in their analysis, then the validity of the study will be called into question. We want and need the best possible study, and if the process is flawed, this will all be an exercise in futility. Truck size and weight issues have significant safety and cost implications. We need to get this right.”
James P. Hoffa, general president of the Teamsters union, emphasized that “what has been made clear is that the DOT’s study on the impact of truck size and weight is flawed. “Congress cannot base policy decisions on this study when the driving public’s safety is at risk
“The on-going problems plaguing the DOT Truck Size and Weight Study need immediate attention and corrective action by the Obama Administration,” contended Joan Claybrook, chair of CRASH.
“If not,” she warned, “this study will become the lottery prize for corporate trucking interests pushing for bigger, heavier and more deadly trucks on our highways. Serious mistakes and chronic missteps by DOT, as we have already seen, will produce a shoddy, inaccurate study that puts corporate profits ahead of public safety.”