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DDOT is broken, but slicing it into pieces is not the way to fix it.
WABA Executive Director Shane Farthing gave this testimony at a DC Council hearing on June 4, 2014.
Titlu original
WABA's Testimony on the proposed DDOT Reorganization
DDOT is broken, but slicing it into pieces is not the way to fix it.
WABA Executive Director Shane Farthing gave this testimony at a DC Council hearing on June 4, 2014.
DDOT is broken, but slicing it into pieces is not the way to fix it.
WABA Executive Director Shane Farthing gave this testimony at a DC Council hearing on June 4, 2014.
TESTIMONY ON BILL 20-759, THE TRANSPORTATION REORGANIZATION ACT OF 2014
Members of the Committee:
Over the past several years, WABA has testified before this Committee on a number of concerns related to the performance of the District Department of Transportation (DDOT). As representatives of the Districts and regions bicycling community we fully appreciate the motivations for this bill, and applaud the effort to improve delivery on a variety of projects and programs that are presently DDOTs responsibility, and at which DDOT is presently failing.
However, we are concerned that the structure proposed in this bill does not address the key problems that limit DDOTs effectiveness, and may actually create more difficulty and delay.
Modal Concerns Regarding the Location of Bike Programming in the District Transit Authority
WABA is deeply concerned that under this bill, bicycle planning and implementation is being shoehorned into a new entity constructed for a different purpose, where it is likely to be marginalized and underfunded. The responsibility to build and maintain a transportation network that serves the needs of District residents who bike and walk is a fundamental governmental responsibility that should not be ceded to a corporate board comprised of members with no public accountability and no qualifications in bicycle planning.
Nowhere in the world is the responsibility for bicycling taken from a transportation agency and given to a transit authority. It simply makes no sense, as biking is not transit by any normal definition. Bicycling is transportation. It needs transportation planning. It needs transportation design and construction management. It needs transportation funding.
Despite our shared concerns about DDOTs delivery of bike projects, moving the responsibility for biking to a transit agency would be a move from bad to worse. Presently, there are internal organizational issues at DDOT that limit its ability to deliver on biking projects. But those internal flaws can be addressed by the proper deployment of just a few additional FTEs and by a project-based management system, as we can see working for their internal AWI team.
If this proposal is enacted and biking is instead shoehorned into a transit agency, it will then be systemically marginalized and underfunded in a way that will be much more difficult to correct in the future. Federal funding for bike and pedestrian projects would be stalled in additional bureaucracy, as it would have to be routed through the transportation agency anyway. And in every competition for resources, a transit agency will choose transit over other things, including investment in biking and walking.
Structural Concerns about the Regulation of Public Space
It is important to remember that, despite its name, DDOT is not just the Districts transportation department. In reality, it is the Districts department of all things public spacewhich is a somewhat broader mandate. And the breadth of that mandate is important. While it is correct for the Council to
ask whether DDOTs mission has become so expansive the it simply cannot deliver on everything, it is equally important to ask whether that breadth plays an important role in providing flexibility for innovation and improvement that would by stymied by bureaucracy and parochialism if multiple agencies were involved.
As the District continues to grow in population without growing in area, pressures will continue to mount on exactly how our public space can be put to the best use for a variety of purposes. The Districts ability to adapt the use of its public space to the evolving needs of a growing population is critical to capturing the economic and sustainability benefits offered by increasing density. We must be able to balance the needs for cars and bikes, pedestrians and delivery vehicles, street trees and sidewalks, catchbasins and cafes. We must be able to flexibly optimize public space to the needs of the people.
Are we able to do this presently? No. But flaws in internal structure, organizational management, and leadership can be corrected with new leadership and new systems, so long as the underlying structure makes tradeoffs and attempts at optimization possible.
However, if the system is realigned so that our public space is to be managed by multiple entities with competing interests and no shared motivation to compromise, gridlock will result. An agency that exists for the sole purpose of dealing with parking will forever prefer parking and the revenue it affords. Similarly, an agency that controls space only when that space contains street trees will argue for street trees in every space. Ultimately, the parochialism that will result from splitting and isolating particular uses of public space among various agencies will make compromise and innovation of the sort that leads to removing three parking spaces to increase bike travel on a road by 65% impossiblethough this just happened with the installation of the cycletrack on L Street.
I do not defend DDOTs present capacity to deliver on the needs of residents. But I do believe that the ability to flexibly manage the Districts public space to balance the needs of transportation, economic activity, environmental activity, and other needs is criticaland this bill, in splitting the management of public space into numerous agencies each responsible for discrete pieces, removes the necessary flexibility.
Timing and Capacity Concerns
In addition to concerns about the placement of biking responsibilities and the management of public space, we are also concerned about the timing of this proposal and the affect it will have on the Districts ability to move projects forward.
As you know, the long-awaited MoveDC transportation plan was released last week. Weighing in at several hundred pages, it describes the Districts multimodal plan for the future of transportation, and it will be before this Council within thirty days.
How is the public supposed to simultaneously comment on DDOTs substantive plan for the future of transportation and a plan to reorganize the agency responsible for creating and implementing that plan? Rather than simultaneously proposing a new org chart and a new long-range plandeveloped in isolation from one anothershould we not work first agree on a long-range transportation goal, then design the organizational scheme that will best bring it to reality?
Meanwhile, residents are ready for the backlog of projects to move forward. For eighteen months DDOTs standing excuse for its failure to move forward on new projects was the need to finalize the MoveDC plan. Now, the final plan has been released, and it is time to expect movement on the projects it contains.
This will not happen quickly if the administrative reorganization proposed by this bill takes place, however. Such reorganization does not happen quickly. It involves duplication of functions, movement of people and offices, filling of new FTEs, and creation of new structures and org charts.
My first experience working for the District government came in 2006, when as a Fellow I was asked to join the newly formed DDOE to help sort out some of its permitting processes. The agency had been carved out of a combination of DCRA, DOH, DDOT, and DPW to consolidate environmental review rather than have it spread across multiple agenciesthe opposite of what is proposed here regarding public space. And for the better part of two years, the agency struggled to find its footing, operating with large numbers of vacancies, using forms and wearing jackets with the wrong agency name listed, and being listed as a high-risk grantee of federal partners because it had no track record of achievement or demonstrated capacity to operate programs with federal funds.
The focus of a new agency, at least at the outset, will be to figure out what it is and build capacity to be that. We have seen it with DDOE. We have seen it with the SEU. Frankly, we still see it in DDOT as it is structured today.
Changing the organizational structures of entities within the DC bureaucracy by pulling one agency apart and creating others presents the District with enormous transaction costs. In this case, those transaction costs will likely be at least a year of startup and capacity building that could otherwise be spent on solving the problems this Committee, WABA, and residents want solved.
Recommendations & Conclusion
Fundamentally, WABA agrees with the motivation underlying this proposal. DDOT has failed to deliver on such a variety of its responsibilities that change is needed. But what is needed is not a bill that splits our public realm into battling bureaucratic constituencies and costs the District years of actual progress. What is needed is leadership and management at DDOT that understands the purpose of its breadth and undertakes the internal realignments and education and work to deliver on its responsibilities.
Unfortunately, such internal and leadership changes are not within the direct purview of the Council. So it is understandable that councilmembers seek an alternate solution that can be effected through legislation. But the solution to internal agency problems is unlikely to be an external reorganization that subjugates biking and walking within a transit agency, divides public space responsibilities into further silos, and relies on a new cast of characters and agencies to reach capacity before they can act.
To further the goal of improving DDOTs performance for bicycling and for project delivery in general, WABA recommends:
Limit the authority of the District Transit Authority, if created, to transit operations for Circulator, Streetcar, and Capital Bikeshare. Bicycling and walking policy, planning, and implementation should not be housed in a transit corporation.
Do not create an agency with a budgetary and parochial interest in the maintenance of parking. This inappropriately elevates parking over all other potential uses of public space, which do not have their own agencies. (The need to bring parking under a single, coherent system could be addressed by housing a robust parking division within any of the agencies currently involved in parking matters.)
Promote structures that allow multi-modal tradeoffs and flexibility in the regulation and use of public space, as opposed to narrowly defined agencies that will compete rather than cooperate.
Allow time for the full public vetting and Council approval of the MoveDC plan before significantly changing the implementing agency, to avoid undermining the MoveDC process and confusing the public.
Thank you for your commitment to improving the Districts structure for managing its public space and transportation, and for the opportunity to provide our input on behalf of the Districts bicyclists.