An open letter to the leadership of the Transportation Research Board

I write as a transportation professional with over 30 years of experience working for state Department of Transportations, both in Maryland and Pennsylvania.  My specialty is in historic preservation and I have a PhD in anthropology with an emphasis in archaeology from The Pennsylvania State University. I have been a friend or member of ADC50 (originally A1F05) during this time and have served on several 25-25 research panels.  In 2001, PennDOT chose to award me a Star of Excellence, which honors the top half of one-percent in the agency.  In 2012, the Pennsylvania State Historic Preservation Officer gave me a Visionary in Historic Preservation Award.  I’d like to think I know my business.

The Transportation Research Board has recently undertaken a complete overhaul of TRB’s Committee Structure. The new TRB structure renumbers the ADC50 Committee on Historic and Archaeological Preservation in Transportation (AME60), and moves it from the old Environment and Energy Section (ADC00) to a new Transportation and Society Section (AME00) within a new Sustainability and Resilience Group (AM000).  The Historic and Archaeological Preservation in Transportation Committee still exists, for which I probably should be grateful as many other worthy Committees have been eliminated and/or consolidated.  However, the move into the new Transportation and Society Section and a review of fellow committees within the Section and Group immediately reminded me of a scene early in the movie Animal House.   Faber College freshmen Larry “Pinto” Kroger and Kent “Flounder” Dorfman are seeking to join a fraternity and come across the prestigious Omega Theta Pi house party.  Almost immediately they are sized up and ushered into a “special” room containing all of the potential pledges that are deemed unworthy.  The image of that room, with all its lost souls, says all you need to know about Omega Theta Pi.

The Island of Misfit Toys

The list of Committees within the Transportation and Society Section also says all you need to know about TRB decisionmaking.  Historic and Archaeological Preservation in Transportation (AME60) is buttressed by not one, but two Federal laws – Section 106 of the National Historic Preservation Act, and, Section 4(f) of the US DOT Act of 1966. One can make the case that the role of the Committee extends beyond these two laws, especially with regard to Planning and Environmental Linkage (PEL), but by and large the Committee’s work is focused on implementation of these two laws.  

AME60 is possibly the only Committee other than AME30 in the Section with a focus underpinned by Federal legislation.  Surveying the other Committees in the Section, it appears AME60 has truly been moved to the island of misfit toys.  Rightly or wrongly, most engineers will react to what they are legally required to do, not what they morally should consider.  It is the nature of working in the Land of Engineers.  Archaeology and historic preservation have a pair of 50-year old laws underpinning our work, along with supporting Federal Regulations.  If I had a nickel for every time I had to tell an engineer, “because it’s the law,” I would be writing this letter from my personal island in the Bahamas.  On these grounds alone, AME60 is misplaced.

Going through each Committee within the Section:

• Equity in Transportation (AME10)  is the old ADD50, the Committee on Environmental Justice.  From their web site, the Committee on Environmental Justice identified, advanced and published research to expand understanding of the effects and implications of transportation policies, procedures and actions on minority and low-income populations (EJ populations), and sought to improve evaluation tools and methodologies.  Environmental Justice is supported by a 1994 Executive Order (12898), but no specific legislation.  In 2017 and 2019, Congress tried unsuccessfully put into effect laws to support Environmental Justice.  And we all know how tenuous Executive Orders are at this time.
• Women’s Issues in Transportation (AME20) is the old ABE70.  From their web site, the people who proposed and supported the Women’s Issues in Transportation group recognized the need to consider gender as an important factor in the way people travel. Is there underpinning legislation to support this worthy mission?  Or to put it bluntly, is there any legislation that mandates that engineers and designers consider gender?
• Native American Transportation Issues (AME30) is the old ABE80.  From their web site, the Native American Transportation Issues Committee is concerned with research and practice pertaining to transportation issues on or near tribal lands and communities or affecting tribal historical or cultural properties wherever located. Tribal transportation issues include all modes of moving people and goods from one place to another, all relevant agencies including tribal, state, federal, regional and local providers, and all relationships and interactive processes of various governmental units – tribal, federal, state and local – with regard to the development, planning and administration, coordination, and implementation of transportation laws, policies, plans, programs and projects.  ABE80 has worked closely with ADC50 in the past and it would probably be appropriate to put both Committees in the same Section (but see below).
• Transportation in the Developing Countries (AME40) is the old ABE90.  Other than it being part of the old ABE Policy Section, it is unclear why this Committee is put with the others in this Section.  And it goes without saying, there is no Federal legislation underpinning the activities of this Committee.
• Accessible Transportation and Mobility (AME50) is a combination of the old ABE60 and APO60 Committees.  From their website, the Committee’s mandate is to educate everyone on the issues and gaps related to mobility needs for people with limited transportation options – people with mobility, sensory and cognitive disabilities; older adults; and individuals without private transportation.  There appears to be no Federal legislation underpinning the activities of this Committee, although some of their work would encompass the Americans with Disabilities Act.
• Transportation and Public Health (AME70) (new*) – This probably comes out of the NCHRP D20112 – Panel on Research Roadmap – Public Health and Transportation.  I don’t believe there is Federal Legislation to focus activities of the Committee, although there should be.
• Community Resources and Impacts (AME80) (new*) – This probably comes from the roots of ADD20 – Standing Committee on Social and Economic Factors of Transportation.  Other than the relatively vague missives in the National Environmental Policy Act, there is no strong legal underpinning for issues related to this Committee.  I had specific experience working with community concerns over small bridges that were valued by the local community but did not fit within the eligibility criteria of the National Register and hence weren’t subject to Section 106 or 4(f).  Trying to wheel the Department around to seriously considering these as resources within NEPA was a big lift, without mandating legislation.

The NEPA Umbrella – RIP(ped)

As a cultural ecologist, one of the things that is drummed into your head is the concept of the interplay between people and the environment, especially how homo sapiens is just one species in an ecology of earth, perhaps the biggest and baddest species, but still part of the system.  I have been able to align my education and training in my transportation career precisely because of the nature and role of the National Environmental Policy Act (NEPA)

The purposes of the National Environmental Policy Act (NEPA) of 1969 are: 

To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. (my emphasis)

In Section 102 (A), Congress directs that

… all agencies… shall utilize a systematic, interdisciplinary approach which will insure the integrated use of the natural and social sciences and the environmental design arts in planning and in decisionmaking which may have an impact on man’s environment. (my emphasis)

I think it is necessary to restate the purpose of NEPA and to remind everyone that NEPA is integrative, system focused, and recognizes the interplay between human activities and the environment within which they operate.  The NEPA umbrella is a concept that has emerged from the 1969 legislation.  Multiple laws, executive orders and regulations are considered in the NEPA process. Not only are environmental features studied; so are impacts to the economy and society.  For my entire career, the NEPA umbrella has been a central starting point in any work.  Preliminary design does not end until a NEPA document is approved, which means all of the umbrellaed laws have been addressed, including Section 106 and 4(f).

In the old TRB structure, the NEPA umbrella was reflected in the makeup of ADC00 – Environment and Energy: Environmental Analysis (ADC10); Air Quality (ADC20); Ecology (ADC30); Noise and Vibration (ADC40);Historic and Archaeological Preservation (ADC50).  Each Committee had underpinning legislation tied to NEPA.

Whither NEPA in the new TRB structure?  It  has been moved to the Data, Planning, and Analysis Group as Environmental Analysis and Ecology (AEP70).  The old ADC30 on Ecology has been merged into that Committee.  Noise and Vibration (old ADC40) has been brought over to that group as AEP80.  Air Quality joins Historic and Archaeological Preservation in the Sustainability and Resilience Group, but under the Transportation and Sustainability Section as AMS10.  The old NEPA umbrella has been shredded, at least as far as TRB is concerned.

As an archaeologist, one of the things that is drummed into your head is the concept of taxonomy and classification.  This is particularly true in artifact analysis, whether it be pottery or lithics.  The goal of classification is to put like things together and separate them from things that are not the same, for the purpose of a higher analysis and understanding.  Often the goal is creating a chronology, but in the past (and to some degree still relevant), types reflect a cultural continuity, e.g., the Beaker people.  A society could be reflected in a particular artifact type.

There is a natural tendency to categorize and classify.  It’s a very human thing to do.  But classifications should be useful in some way.  You can certainly argue that NEPA analysis is an analysis just like planning analysis, and perhaps belongs in that Group.  However, to strip away half of the Committees that used to sit under the NEPA umbrella, e.g. ADC20 and ADC50, and spread them to the winds does not seem useful.

Sustainability and Resilience!

The heavy impact of a rapidly warming planet on infrastructure is indisputable and should be a matter of great concern to all of our public leaders.  It is naturally the role of TRB to get ahead of this crisis and advise agencies.  TRB is right to have created a new group on Sustainability and Resilience.

That being said, when I actually look at the composition of the Group and its sections, I get that sinking feeling that: (a) the leadership of TRB could not agree on how to structure the new Group; (b) they are clueless about how TRB should address the climate crisis; or (c) don’t care.  Simply stated, most of the Committees in the Transportation and Society Section have nothing to do with Sustainability and Resilience, e.g. Women’s Issues in Transportation, or Historic and Archaeological Preservation?!  Many of the other Committees in the Group seem like duplicates, e.g. AME70: Transportation and Public Health and AMS10: Air Quality and Green House Gas Mitigation.  Air quality is a public health issue. That’s why it’s measured. AMR 20: Disaster Response, Recovery, and Business Continuity and AMR50: Natural Hazards and Extreme Weather Events are two sides of the same coin.  

Beyond that, you could argue that real and important Transportation Planning (Section AEP00) must start with Sustainability and Resilience principles, so that maybe it would make more sense to put that entire AM000 Group into Planning, or break AE000 into Data and Analysis in one Group and (real) Planning that considers the climate crisis into another.

Why Should Anyone Care?

I’ve spent over 2,000 words complaining about the new Committee Structure.  Should anyone outside of TRB or even inside TRB even care?  Most committees are being carried forward.  AME60 will exist and persist.

In TRB, structure is resources, more specifically allocation of finite resources.  Committees compete within Sections, Sections within Groups.  It affects budget, symposia allocations, the ear of the Section or Group coordinators, and even the ability to communicate with TRB Leadership.  The balancing of Groups and Sections is the balancing of all of these competing interests, and fairness should dictate that like competes with like.  There is little cohesive within the Transportation and Society Section (AME000) or even within the Sustainability and Resilience Group (AM000).  It is as if all of the scraps from the original cuttings of Groups and Sections were swept up and put under a new rug.  In the process, the NEPA umbrella is discarded.  Important and critical work for TRB with regard to climate change impacts is diluted.  Other Committees that probably should have standing at a high level, such as AME20, are disrespected.  AME20 more realistically should be under the Executive Management Issues Section (AJE00).

To the degree that the new TRB structure is meaningful to transportation professionals across the country, this organization is yet another signal to transportation engineers that people issues are wholly secondary to concrete and asphalt.  People are unpredictable. They complain.  They challenge.  People stand up to the elegantly designed roadway and bridge plans and dare to suggest that transportation infrastructure need to be harmonious with society, not apart from it. People suggest that some of the important factors, like accessibility, or appreciation of the past, are difficult to measure, but nonetheless important to consider.  They are the ones that suggest that the welfare of the bugs and bunnies is also the welfare of all of us.  Constituting the Sustainability and Resilience Group the way it has been put together just seems like a kick in the ass.

Finally, although this might be much ado about very little, we should remind ourselves that money spent on archaeology and historic preservation in transportation projects far outstrips the funds that the National Park Service provides. In virtually every state, DOT’s spend more on archaeology and historic preservation studies than any other agency or group.  So even small signals in the transportation sector can reverberate to the larger preservation community.  To paraphrase Metternich, when transportation archaeology sneezes, historic preservation gets a cold.