MDOT’s Five-Year Transportation Program – our comment

August 21, 2023

The Michigan Department of Transportation Five-Year Transportation Program has been released and is open for public comment until Sept. 8, 2023. 

Please consider writing your own comment and submitting it by Sept. 8.

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LMB’s full comment is as follows:

Thank you for the opportunity to provide comment on the MDOT Five-Year Transportation Program (5YTP.) MDOT is taking some significant steps to improve safety for people who bike and walk, although there are many opportunities for improvement, including places where the 5YTP could better support the focus area of Complete Streets and multimodal approaches. Please see our comments by page below:

Page 6: Complete Streets / Multimodal focus area. Protected bicycle lanes are called out as the first of the highlighted enhancements yet are only mentioned once in the rest of the document – as part of the Gordie Howe International Bridge project on p. 8. Are other protected bicycle lanes planned for construction as well – for example, as part of the US-12 Michigan Avenue project? How many miles in total?

Page 9: City of Port Huron, Blue Water Bridge. The Complete Streets icon is present, but the description does not mention any pedestrian, transit, or bicycle improvements. It is currently not permitted to cross the bridge as a pedestrian or bicyclist, and no public transit service operates across the bridge.

Page 13: Bar graph titled “Estimated Capital Highway Program Funding FY 2024-2028: $11.9 billion”. The graph shows that $1,053,000,000 in state revenue (including routine maintenance) is expected for FY 2024. 

MCL 247.660k(2) states, “Of the funds allocated from the Michigan Transportation Fund to the State Trunkline Fund and to the counties, cities, and villages, a reasonable amount, but not less than 1 percent of those funds shall be expended for construction or improvement of nonmotorized transportation services and facilities.” This requirement may be “met as an average over a reasonable period of years, not to exceed 10.”

1 percent of the FY 2024 state revenue total shown here is $105,300,000. Does MDOT plan to expend more than $100 million in FY 2024 on the construction or improvement of nonmotorized transportation services and facilities? Has MDOT met the 1% requirement as an average over the past 10 years? Is a full summary of these projects and their costs available?

Page 15: FY 2024 Highway Program. Why are Safety and Systems Operations and TSMO combined into a single $195M entry? How much is MDOT investing in each of these individually in 2024? 

“Nonmotorized facilities” are listed as part of “Other state and federally funded programs” along with several other entries, all totaling $95M – less than the $105 million that appears to be required by law for nonmotorized transportation services and facilities alone.

Page 20: Safety Goals. Michigan’s transportation system is killing more people each year. It is not meeting MDOT’s safety goal or even making steady progress toward MDOT’s safety goal. The language used here – “As seen below, fatalities and serious injuries statewide have been on the rise since 2018” – fails to grapple with this stark reality. 

The text of the paragraph does not match the data in the graphs, with the text attributing 1,131 fatalities to 2022, while the graph depicts that total for 2021. The correct number for 2022 is 1,123 – 31 more deaths than the goal for 2022 set in the Strategic Highway Safety Plan.*

The sentence that follows deserves its own page at a minimum: “To address this, MDOT is implementing the Safe System Approach, which acknowledges human mistakes and vulnerability, and designs a redundant system to prevent crashes and ensure those that do occur do not result in serious injury or death.” How is MDOT implementing this approach? How much is MDOT investing in systems change to re-orient all its patterns, habits, and practices around it? Is this effort part of the $195 million consolidated entry for Safety and Systems Operations and TSMO?

The Strategic Highway Safety Plan identifies Engineering Infrastructure and Traffic Safety Engineering as the emphasis area with the greatest number of fatalities and serious injuries by far from 2017-2021 (p. 15 of SHSP.) How is MDOT implementing a Safe System Approach in this area?

On p. 18 and 19, MDOT identifies specific dollar values for the investments needed to attain trunkline pavement and bridge condition goals. What investment is needed to achieve Michigan’s safety goal of Zero Deaths, to “prevent crashes and ensure that those that do occur do not result in serious injury or death”?

This section also mentions the new BIL requirements for state safety programs but does not identify the percentage of VRU fatalities in Michigan, identify planned HSIP-funded projects to address the safety of VRUs, or indicate their cost. It does not explain whether Michigan is conducting a VRU Safety Assessment, who is leading the assessment, or how the public can engage with it.

If safety is a priority, it deserves more of a presence in this document than two-thirds of a page.

On August 3, a release from the Michigan Office of Highway Safety Planning noted that from 2020 to 2022, 103 bicyclists were killed in Michigan, an increase of 64 percent over the previous three-year period. As OHSP director Katie Bower noted, “The death of even one bicyclist is one too many.” We believe that a safer transportation system is possible. We believe that reaching zero deaths is possible. We believe that the state’s first priority must be the protection of its citizens from violent death, and that MDOT is fully capable of achieving its safety goal with sufficient attention, focus, and investment.

We request a response to our comment at your convenience. We plan to publish this comment and your response on our website,, while inviting our supporters to submit their own comments. Thank you again for the opportunity to offer comment on the MDOT Five-Year Transportation Program. We value MDOT’s efforts to improve the Michigan transportation system for all users and encourage you to do all in your power to achieve zero deaths. 

* See attached visualization.

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