Risk-Based Asset Management Plan

We commend the Federal Highway Administration (FHWA) for proposing a rule that establishes a process for state Departments of Transportation (DOTs) to develop Asset Management Plans with the goal of maintaining and improving our nations roads and bridges as part of the National Highway System. Members of the Portland Cement Association (PCA) and the American Concrete Pavement Association (ACPA) look forward to continuing to support state DOTs by providing high quality materials and technical expertise to assist in constructing, rehabilitating, reconstructing, and repairing our nations roads and bridges. The following comments are intended to help improve the proposed rule. While we support the establishment of Asset Management Plans to assess and analyze the condition and performance of our roads and bridges, we believe the proposed rule lacks a key component that has been traditionally included in previous Asset Management Plans. As outlined in the attached comments, we are concerned that proposed changes to the definition of Life Cycle Cost Analysis (LCCA) will cause confusion and inefficiencies among state and local DOTs as they allocate limited tax-payer resources toward infrastructure investments. To address those concerns, we are asking FHWA to make specific changes to its proposed rule. We appreciate the opportunity to submit comments and hope that you will depend on PCA and ACPA to be partners in improving our nations infrastructure.