Preventive Maintenance Questions and Answers
December 16, 2004
Question (Q1): For use of HBRRP funds for preventive maintenance, how do the provisions of this memo relate to the previous condition (from HIBT 1/02 memo) requiring the use of a systematic approach? Does this now allow preventive maintenance, using HBRRP, without this requirement or talk about a so-called systematic process or BMS?
Question (Q2): How would a person reading this memo know that you need something like a BMS to select projects for this type of work? Suppose you find a bridge in your inventory that needs to be painted. You can justify that it is a cost effective strategy. Your economic evaluation could be for that bridge alone showing that you do save money on this bridge by painting it and preserving it now. It does not require that you look at other bridges in your inventory in similar condition and rate them based on cost effectiveness through life cycle cost analysis.
Answer (Q1, Q2): While the January 11, 2002 memo on HBRRP funds for PM was superceded by the more generic October 8, 2004 memo on PM eligibility, the intent to have a systematic process for identifying PM activities has not changed. We agree that it is still very important to use a systematic process in identifying PM activities, regardless of the funding source. Furthermore, as indicated in the HIBT memo of January 2002, we feel that a systematic process is required in order to meet the intent of 23 U.S.C. 144 and 116 (d).
The third paragraph of the October 8 memo states that the division offices are encouraged to work with their DOTs to establish a program that identifies eligible PM measures. It also quotes the AASHTO definition that includes the phrase "a planned strategy of cost-effective treatments..." (emphasis added). In our interpretation, the need to establish a program and a planned strategy is equivalent to having a systematic process. Without a systematic process, what is the strategy, how is it planned, and how do you determine if the activities are cost effective?
Question (Q3): The January 11, 2002 memo on HBRRP Funds for Preventive Maintenance provided instructions for coding these projects in FMIS so that we could track bridge preservation activities in the future. Are the coding instructions rescinded?
Answer (Q3): Even though the previous memo was rescinded, the FMIS coding instructions from the January 11 2002 memo are still applicable. For the purposes of entering bridge preservation activities in the FMIS, use the improvement type code = 14, "Bridge Rehabilitation - No Added Capacity."
Question (Q4): The first paragraph of the October 8, 2004 memo states that experience has shown that when properly applied, PM is a cost effective way of extending the service life of highway facilities. Why does that make it eligible for federal aid funding. Is there some legal reference we are missing here?
Answer (Q4): Title 23, section 116(d) provides the legal basis for making PM eligible for federal-aid: "A preventive maintenance activity shall be eligible for Federal assistance under this title of the State demonstrates to the satisfaction of the Secretary that the activity is a cost-effective means of extending the useful life of a Federal-aid highway."
Question (Q5): Can Federal-aid funds be used for maintenance being performed on a force account basis by State crews? Have we ever determined how heavy the maintenance activities would have to be so that the State could not do it with its own forces and would be required to use competitive bidding process in 23USC112? My thoughts are along the lines that a deck removal would require the competitive bidding process where a bearing replacement would not.
Answer (Q5): First, the preventive maintenance activities would have to meet the conditions established in the October 8 memo, and would need to be activities identified through a systematic process and extend the service life of the bridge or pavement. To use its own forces for the work, the State would need to demonstrate that to do so would be in the public's interest and a significant advantage (cost, materials, expertise, etc.) when compared to competing the work to contractors. Depending upon the nature and extent of the work throughout the State or region, it could be appropriate to use HBRRP funds for the crew's work on a full-time or part-time basis.
Question (Q6): Are all maintenance items now eligible for FA? Have we defined what maintenance is not eligible for Federal-aid?
Answer (Q6): The October 8 provides broad guidelines for consideration when determining eligibility for Federal-aid funding on preventive maintenance activities. The intent of the memo was not to make all maintenance eligible for Federal-aid funding. Certain maintenance activities that are considered routine maintenance remain a State funded responsibility. Routine maintenance is defined as "Maintenance work that is planned and performed on a routine basis to maintain and preserve the condition of the highway system or to respond to specific conditions and events that restore the highway system to an adequate level of service." (AASHTO Subcommittee on Maintenance Pavement Preservation Supplemental Glossary of Terms for Highway Maintenance Practitioners, August 3, 2004) The memo was intended to support State system preservation programs by making Federal funding available for State programs for preventive maintenance - which extend the service life of the facility.
Question (Q7): Should litter pick-up be eligible based on the theory that the litter might hinder drainage facilities? What about snow removal or roadkill clean-up?
Answer (Q7): Litter pick-up and removal of roadkill are examples of activities that should be classified as routine maintenance. Although these activities often have the secondary benefit of removing material that might otherwise clog drains, that is not their primary intent. Similar logic would apply to snow removal, which is a necessary action for keeping roads passable during winter weather but not inherently performed for preservation of the pavement itself.
Question (Q8): Should graffiti removal be eligible for Federal-aid?
Answer (Q8): A statewide or region-wide program for removal of graffiti from sign faces could be eligible as preventive maintenance, prolonging the functionality of the signs. However, a program for removal of graffiti from bridge abutments, noisewalls, etc. would serve primarily cosmetic purposes and should be considered routine maintenance.
For further information, please contact Chris Newman at (202) 366-2023 or (firstname.lastname@example.org).