Record Keeping Requirements for State Departments of Transportation (2009)

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58 APPENDIX H: AFFIDAVIT OF ENGINEER JONES ) v. ) MHTC ) My name is Mike Engineer. I am the Maintenance Operations Engineer for the southern district of the Missouri Department of Transportation. The southern district includes highway T, in Newton County. I am of sound mind and capable of making this affidavit. 1. The activities of the Missouri Department of Transportation (MoDOT) involve the compilation and analysis of accident data with the goal of identifying and addressing problem locations, i.e. those locations with higher than typical accident rates, in order to evaluate the possible use of federal highway safety funding. 2. MoDoT collects and compiles accident and road condition information and reports, including but not limited to traffic accident detail reports, summaries and studies. Collection of raw data and analysis of this data constitute part of Missouri’s response to the requirements of 23 U.S.C. Sec- tion 152 (a) (1) to “identify” hazardous locations and “assign priorities” for remediation. The data is used to identify and evaluate locations as well as to plan for safety enhancement of potential acci- dent sites and hazardous roadway conditions. The data is also used to develop highway safety con- struction improvement projects which may be implemented by securing federal road safety funds to eliminate road hazards. 3. These activities are supported by federal funds. 4. I have reviewed the requests for production related to the case of Jones v. MHTC and others. Ma- terials requested include those that are specifically gathered pursuant to the provisions of 23 U.S.C. Section 152 and 23 U.S.C. Section 409. 5. This data is used to evaluate Missouri’s highways in order to determine how best to use the lim- ited federal highway safety funds made available by Congress through the federal highway ad- ministration. 6. Federal funding is potentially available to the district for improvements to highway T in Newton County. Further, affiant sayeth not. Mike Engineer Maintenance Operations Engineer