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67 Conclusion State DOTs are progressing toward or have attained compliance with the requirements of 23 CFR Â§ 667. However, agencies have taken different approaches to interpreting the requirements and incorporating the results of their efforts into broader asset management and infrastructure investment decisions and actions. This study sought to document the actions taken to date and planned by state DOTs in this regard. Conclusions About Different Agency Approaches These conclusions draw from the information gathered in this effort to identify differences between agenciesâ approaches and results and determine the factors that have led to these differences. â¢ FHWA opted to include the requirements for identifying and evaluating sites damaged by multiple emergency events in a section of the Code of Federal Regulations (23 CFR Â§ 667) separate from the requirements for the Emergency Relief Program (23 CFR Â§ 668). They issued those requirements in coordination with the asset management regulations (23 CFR 515) because the agency identified a connection between the management of these facilities and an agencyâs ability to address risks related to achieving its asset management objectives (FHWA 2016d). â¢ The synthesis found most agencies have not developed processes that integrate the results of identifying and evaluating sites damaged by multiple emergency events into their asset management practices other than providing summaries in their TAMPs and making the findings available to staff and FHWA. â¢ Agencies that identified the greatest number of sites damaged by multiple emergency events either took a broad view to interpreting the requirements of 23 CFR Â§ 667, often going beyond those requirements in their definitions of qualifying events or locations impacted by multiple events, or had practices in place to retain detailed historical records. â¢ Nearly half of the agencies that responded (19 of 39, 45%) reported having no records of damage due to emergencies prior to 2001. â¢ Lack of data was selected as the greatest challenge to compliance with the requirements of 23 CFR Â§ 667 by the most agencies in the survey (16 out of 42, 38%). â¢ Just over half of the agencies (14 of 27, 52%) that reported identifying at least one site damaged by multiple emergency events provided no response regarding the status of their evaluations to determine alternative strategies for sites damaged by multiple events. â¢ State DOTs most commonly worked with state emergency management offices to identify and evaluate sites damaged by multiple events. â¢ Most states (31 of 42, 74%) were able to comply with 23 CFR Â§ 667 without requiring addi- tional permanent staff. States that did augment staff most commonly did so with consultants (10 of 11, 91%). C H A P T E R 5
68 Asset Management Approaches to Identifying and Evaluating Assets Damaged Due to Emergency Events â¢ Agencies adopted a variety of criteria for defining damage from multiple events having occurred at a common location. â¢ Half of responding agencies (21 of 42) indicated that the results of their analyses were made available to one or more external stakeholder groups. â¢ Most agencies (31 of 42, 74%) had not yet developed written procedures related to compliance with 23 CFR Â§ 667. â¢ Most responding agencies (15 of 18, 83%) incorporated the results of the analysis only into the risk management section of their TAMPs. Only seven agencies reported incorporating the results into other sections of their TAMPs. â¢ Most agencies have not yet used the alternative strategies developed in compliance with 23 CFR Â§ 667 in support of project development. Opportunities for Future Research The following bulleted items highlight knowledge gaps that could be supported by future research efforts. Those opportunities are summarized as follows. â¢ Additional research could seek to build on prior efforts regarding the consideration of resilience in project design to incorporate resiliency into programmatic and strategic practices and processes, such as LCP and developing asset management investment strategies. â¢ Research would enable state DOTs to identify the potential benefits of identifying alternative strategies for sites damaged by multiple events to support decisions regarding the extent to which it is cost effective to expand the definition of âeventâ and âsame locationâ beyond the requirements of 23 CFR Â§ 667. â¢ Research could determine the types and formats of data elements that can be efficiently collected to support the identification of sites and evaluation of alternative strategies for loca- tions damaged by multiple emergency events. Agencies would benefit from the documentation of best or recommended practices for recording, storing, and sharing data about the location, type, and root cause of damage and repairs related to emergency events. Standardization of such data and processes would support coordination between different business units within agencies, such as the responsibility for response and recovery and the units responsible for collecting reimbursements from federal and other agencies. â¢ Changes in maturity would be evident if the survey were repeated following the November 23, 2020, deadline for states to identify and evaluate sites damaged by multiple emergency events on all public roads. Particular areas of focus that could address knowledge gaps remaining after this synthesis include â Documentation and comparison of how different agencies define emergencies and permanent repairs, â Examples of agenciesâ use of evaluation results, particularly to justify the funding of betterments through the FHWAâs ER program, and â Additional documented practices for locating and evaluating sites damaged by multiple events. â¢ To comply with 23 CFR Â§ 667, agencies must develop alternative strategies for addressing the root cause of damage at sites damaged by multiple emergency events (23 CFR Â§ 667.1). Additional research could provide support to agencies identifying and executing appropriate alternative strategies and applying those alternative strategies â To repair damaged assets during recovery from emergency events, â For incorporation into the environmental review process during project development, â To inform the planning and project selection processes, and â To support LCP and other TAMP practices.
Conclusion 69 â¢ Research could help identify the connection, if any, between damage caused by emergency events and disruption of service caused by the events. â¢ Agencies other than state DOTs (e.g., county, municipal, or toll authorities) could benefit from additional research regarding best practices for the collection and retention of data on damage and related repairs resulting from emergency events. Note that the results of FHWA pilot projects on incorporating resiliency into LCP were not available in time for inclusion in this report. â¢ Several agencies have developed software for collecting and storing data on damage from emergency events. The documentation of best or recommended practices for the design and use of such software would support agencies of all types in selecting or developing tools that address their needs and facilitate the sharing of information with other stakeholders.