MDOT’s Response to the LMB 5YTP Comment

October 10, 2023

LMB submitted a comment on the MDOT Five-Year Transportation Program on August 18, 2023. We received the following response today, Oct. 10. Editorial comments are in [bold italics and brackets].

Dear Mr. Penniman,

Please see responses below to your comments provided on the annual Five-Year Transportation Program. If there are any follow up questions or comments, please let us know.

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?

Response: At present, and due to the localized nature of the Complete Streets program, there is not a reliable statewide quantification of miles for protected bicycle lanes. 

The project highlights in the document focus on larger to-be constructed or in process of being constructed projects, such as the GHIB, which inevitably involve road and/or bridge construction, and certain elements that are anticipated as part of their design. One of the goals of the 5YTP is to provide initial awareness of upcoming trunkline (I-, M-, and U.S. routes) projects via the region/county list at the end of the document. This early sharing of this information provides a primer for additional project-level engagement opportunities when they become available as posted on the MDOT website.


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.

Response: The icon, while representing projects with Complete Streets improvements, also includes elements that enhance mobility, including but not limited to transit, and changes that improve safety and/or reduce roadway conflicts. The icon is present for the BWB project due to its inclusion of the building of the onsite examination facility which reduces the risk of undetected hazardous goods moving through local streets as well as improvements to local city streets and entrances to allow clear egress to the plaza, reducing potential for international traffic to interfere with local street users. In addition, while bicycles are not allowed on the bridge, they can be transported free of cost to-from either side. [This is not correct – the MDOT Blue Water Bridge account warns bicyclists that “MDOT personnel cannot transport you across the Bridge for health/safety/liability reasons. Please plan ahead and arrange your own transportation to cross into Canada (e.g. taxi, ferry, etc.)”]

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?

Response: The total for state revenue in all years includes those dedicated specifically for routine maintenance, covering activities such as snow plowing, pothole filling, grass cutting, etc. This is counted in our estimates for total state revenue but is not a part of the funds that are available for project construction.  In FY 2024 alone, the amount established in the Governor’s Executive budget is approximately $476 million. This brings 1% non-motorized requirement to an estimated $50 million or less, which MDOT has and will likely continue to exceed.

[I made a math error here; 1% of $1.053 billion is $10 million, not $100 million. However, the statute does not distinguish between funds dedicated specifically for routine maintenance and funds available for project construction. MDOT’s response does not cite the source for the $476 million figure, and I was unable to locate it in the FY2024-2025 Executive Budget Recommendation (p. B-89 to B-92). MDOT also does not provide support or detail for the claim that “MDOT has and will likely to continue to exceed” $50 million in annual investment in non-motorized transportation services and facilities.]

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? 


Response: Below is a table showing the breakout of the investments under the Safety/System Operations and TSMO categories. This reflects recent changes in projects and funding, including law requiring a transfer of NHPP and STBG funds to HSIP in FY 2024.


Traffic and Safety (T&S) – Delineators $1.5
T&S – Pavement Markings $34.0
Pump Stations $3.5
RR Crossings – Trunkline (Federal & State) $5.0
Safety Programs $27.2
T&S – Signs $19.5
Commercial Vehicle Enforcement $3.0
Intelligent Transportation Systems (ITS) – Capital $30.8
Intelligent Transportation Systems (ITS) – Operations $19.2
Traffic Signal – New Signals $6.2
Operations $65.5
Traffic Signal Modernization $23.4

“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.

Response: Addressed in comment for Page 13.


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.* 

Response: This information is being updated in the finalized 5YTP.


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?

Response: The Michigan Department of Transportation Strategic Highway Safety Plan’s Mission is applying the Safe System Approach through statewide strategies and initiatives that accommodate human mistakes and injury tolerance levels to move Michigan Toward Zero Deaths. The Vision is to eliminate fatal and serious injury crashes on Michigan’s roadways and the goal is to eliminate fatalities from 1,131 in 2021 to 0 by 2050 and to eliminate serious injuries from 5,979 in 2021 to 0 by 2050. 

The SHSP incorporates the SSA; this approach is different from the traditional way of addressing safety. It is based on six core principles: death/serious injury is unacceptable, humans make mistakes, humans are vulnerable, responsibility is shared, safety is proactive, and redundancy is crucial. The SSA shares the responsibility of a crash between five elements: safe road users, safe vehicles, safe speeds, safe roads, and post-crash care. It requires all parts of the transportation system be strengthened, so that if one part fails, the other parts still protect people. It promotes shared responsibility between all stakeholders with the goal of eliminating fatalities and serious injuries.

The SHSP also introduces equity to ensure an equitable investment in underserved communities. Equity will help prioritize safety for all road users, regardless of the mode of transportation, because everyone has the right to move safely in their communities. With the implementation of the SSA and introduction of equity, the SHSP will improve safety for all road users, regardless of their mode of transportation. These changes provide an opportunity to make a significant impact on eliminating road fatalities and serious injuries. Working together, local and state agencies across Michigan can achieve the safety goal of zero deaths.

The SHSP provides strategic direction to the Highway Safety Improvement Program and directs the HSIP funding as MDOT regions submit projects to eliminate fatalities and serious injuries. 

  • The 2023-2026 SHSP incorporates the SSA
    • The Mission, Vision, and Goals of the SHSP is to apply the SSA to eliminate fatal and serious injuries by 2050
    • Incorporating the Safe System Approach into the SHSP ensures repetition and redundancy with safety partners across the state, and helps change the safety culture
    • The purpose is to identify key safety needs, and guide investment decisions to eliminate highway fatalities and serious injuries on Michigan roads
    • Allows all highway safety programs in the state to work together, to align and leverage resources
    • It also positions the state and its safety partners to collectively address the state’s safety challenges
    • Provides strategic direction to the Highway Safety Improvement Program (HSIP) and the Highway Safety Plan (HSP)
    • The Michigan Mobility 2045 Plan, as well as other relevant documents, are in alignment with the SHSP to ensure that roadway safety and the elimination of fatal and serious injuries are a statewide priority
    • Introduces Equity to ensure an equitable investment in underserved communities and prioritizes safety for all road users, regardless of the mode of transportation with the implementation of the SSA

 MDOT is focused on increasing safety for all road users through various methods:

  • Messaging: TZD weekly emails, Safety Saturday on Twitter, brochures, the MDOT Newsroom
  • Education: community events, public website, MDOT’s SSA video and webpage, internal workshops and conferences
  • Best Practices: Region TZD Plans, Mi-TIME training, systemic improvements, proven safety countermeasures, geocoding mile markers in the Upper Peninsula, marking walls on US-131’s S-curve so that first responders can warn motorists and safely assist crash victims, Freeway Curtsey Patrols, snow plow green flashing lights, smart work zone research and MDOT’s many other research projects (just to name a few)
  • Education: The Safe System Approach is proactive, and everyone shares the responsibility in preventing life-threatening crashes.
    • Educating others on this approach so that everyone is on the same page, creates a consistent transportation system across the state and helps us reach our goal of zero.
      • SSA Workshop with the TSSAT (Traffic & Safety Statewide Alignment Team) group and Region Engineers
      • MDOT’s public website contains a page dedicated to the Safe System Approach
      • MDOT’s video explaining the Safe System Approach;
  • Vulnerable Road Users (VRU) are important to TZD efforts
    • SSA focuses on human vulnerability
    • The new VRU Special Rule requiring 15% of Highway Safety Improvement Program (HSIP) funding to address VRU safety if triggered, and the VRU Safety Assessment that states are required to complete as part of the BIL, shift the focus from vehicles to VRUs.
    • MDOT has specific systemic improvements in place tailored to improve VRU safety such as: road diets, pedestrian countdown signals, lighting, shoulder widening, bulb out/curb extensions, VRU specific Road Safety Audits, just to name a few

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?

Response: MDOT TZD Efforts:

  • Messaging:
    • TZD weekly messages via email –
    • Safety Saturday messages on Twitter in the form of “Did You Know?” messages
    • Safety brochures on the MDOT website
    • MDOT Newsroom
  • MDOT Best Practices:
    • Adopted the TZD National Strategy
    • Regions complete TZD Plans to identify and address issues leading to traffic fatalities in their areas. The Plans guide their HSIP projects.
    • Mi-TIME Training
    • The Superior Region geocodes mile markers to help EMS dispatch faster
    • Systemic improvements in place to improve safety
    • Grand Region marked locations on the S-curve for first responders to park vehicles in the event of a crash to prevent secondary crashes
    • TOCs provide information to warn the public and keep first responders safe
    • Freeway Curtesy Patrol
    • Emergency pull-off locations along the freeway
    • Smart Work-Zone research
    • Snowplow green flashing lights to increase visibility and improve safety
    • MDOT’s many research projects to improve the safety of all road users
    • Internal learning opportunities – SSA Workshop, TSMO and TranspoCon conferences
    • MDOT has started to compare fatal and serious injuries with environmental justice zones to determine locations where there are a disproportionate number of fatal and serious injuries.
    • Utilize FHWA’s proven safety countermeasures and strategies
    • Road Safety Audits (RSAs) are a formal safety performance examination by an independent, multi-disciplinary RSA team, and are performed on state trunklines and non-trunklines
    • Local Road Safety Plans help local agencies create a prioritized list of improvements and provides a framework to accomplish those safety enhancements
  • Implementing the Safe System Approach (SSA)
    • The tool MDOT will use to combat the rise in fatal and serious injury crashes, and it will be a part of our projects moving forward.

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”?

Response: Changing the Culture of Safety

    1. Toward Zero Deaths focuses on creating a culture of safety because no one should be killed or seriously injured while using the roadway network
    2. The Safe System Approach is the tool we will utilize to achieve this vision
    3. A Safe System needs to be in place if we are to achieve zero deaths and serious injuries, and the Safe System requires the TZD culture that places safety first when making roadway system investment decisions
    4. We need to remember that what we do matters and safety is everyone’s concern – MDOT is taking the lead


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.

Response: The VRU assessment is currently being developed with a quick turnaround due date of November 15, 2023.  We have brought on a consultant with a multi disciplined group to direct this work (myself – Carissa McQuiston is the official PM on the project). The public has been engaged through many previous efforts – this will be a synthesis of all those efforts due to the accelerated timeline. 

Thank you,

MDOT 5 Year Transportation Program Team

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