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Note: this document was superseded by Guidance on Highway Preservation And Maintenance on February 25, 2016

Subject: Information: Preventive Maintenance Eligibility Date: November 26, 2001
From: /s/ original signed by
King W. Gee
Program Manager, Infrastructure
Reply to:
Attn. of:
To: Mr. David C. Miller
Division Administrator
Juneau, AK

During the past year, the Alaska Division engaged in a discussion with the Office of Asset Management and others to refine definitions in the maintenance and preservation area. This program area is covered by several implementation memoranda, and a consolidated national policy is under development based on these memoranda and other existing Federal regulations. In the interim, we have asked that each division consider developing statewide local agreements using the implementing memoranda. To help you formulate these agreements, we offer you our comments based on the attached list of maintenance activities from the Alaska Department of Transportation and Public Facilities (ADOT&PF) submitted by John Lohrey of your staff.

To date, seven policy memoranda have been issued by FHWA, which pertain to preventive maintenance and its eligibility. The purpose of these memoranda was to implement legislation and to provide guidance on approval of Federal-aid preventive maintenance projects. Some examples of work which could be considered as preventive maintenance were included. In 1997, the AASHTO Standing Committee on Highways adopted a preventive maintenance definition containing some disagreements with the description of preventive maintenance activities provided in the earlier FHWA memoranda. Recognizing the discrepancies, some FHWA division offices started sending inquiries to FHWA Headquarters asking for clarifications. As a result, an initiative to clarify standard national policy for Transportation System Preservation (TSP) eligibility has been started. A work group of representatives from division offices, resource centers, and Headquarters dealing with construction, maintenance. safety, and operations is being formed to work on the necessary policy, guidance and technical support for the TSP program.

The memoranda mentioned above will continue to serve as the guidance for division offices for eligibility determinations until a consolidated national policy is established in early 2002. The memorandum of March 21, 1996, states that considerable flexibility remains so that each State, in cooperation with division office and based on sound engineering analysis, can determine the cost-effective strategies for extending the service life of existing pavements, bridges, and essential highway appurtenances on Federal-aid highways." Overall this is the intent of the legislative changes and will serve as the basis for our consolidated national policy.

We appreciate the opportunity to comment on the ADOT&PF's preventive maintenance eligibility guidelines. We trust the comments and guidance will assist you in finalizing a working agreement with ADOT&PF. We would be interested in receiving a copy of this when completed. If there are any questions. please contact Celso Gatchalian at (202) 366-1342 or Julie Trunk at (202) 366-1557.


Preventive Maintenance

(Responses in italics)

Pavement Surface

Eligible - Crack sealing, asphalt surface treatments, rot filling, profiling, milling, and overlays or replacement of the roadway surface when these activities are recommended by the pavement management system as a cost effective means of extending the life of the roadway. Correcting permafrost damage is an eligible activity.

The above maintenance activities are recognized as preventive maintenance as described in the Policy Memos. However, correcting permafrost damage is not a Preventive Maintenance (PM) activity since it requires more than surface type work and is structural in nature making it eligible for federal participation as a roadway rehabilitation need.

Not eligible - Pothole patching or very short sections of asphalt surface treatment or overlay. A length of road must be long enough to be identified as needing treatment in the pavement management system to be eligible for federal-aid. Applying calcium chloride or other dust stabilizer to gravel roads is not eligible.

Pothole patching and other spot repairs are considered routine maintenance and thus, not eligible for PM funds. Pothole patching as part of preparation for PM however could be included in the cost of PM treatment. Applying calcium chloride or other dust stabilizer to gravel roads could be a cost effective treatment, on graded and properly drained roadway, that can extend the service life of the road Alaska and several other states have many miles of unpaved federal-aid system. Stabilizer and dust palliatives offer both performance and environmental benefits. Therefore surface stabilization can be eligible for federal-aid funding as Preventive Maintenance.


Eligible - Upgrade end treatments to current standards. Replacing substandard rail adjacent to pavement overlay or reconstruction areas is encouraged. When working on guardrail, the length of need will be checked.

These activities are considered rehabilitation.reconstruction and should be considered eligible for federal-aid other than Preventive Maintenance. For a PM project to be approved, the Stale should be expected to meet safety and ADA needs or have the work identified as a project in programmed work.

Not eligible - Replacing hit sections or replacing damage done by snow plows.

Isolated or random damage repair/replacement is considered routine maintenance.

Lighting and Signals

Eligible - Replacing poles, light fixtures, or signal heads with new, improved products in a roadway corridor. A systematic program to replace bulbs or LED signals that are near the end of their projected service life is eligible. Also, a systematic program to evaluate and repair signal/luminaire pole bases for bolt fatigue or proper breakaway function would be eligible if the total scope of work was of sufficient magnitude.

The above eligibility descriptions are considered accurate and eligible for PM or regular Federal aid funding as rehabilitation/reconstruction.

Not eligible - Replacing (occasional) burned out bulbs or replacing damaged poles.

This work would be considered routine maintenance and thus, not eligible for PM funding.


Eligible - Area-wide striping projects using materials as recommended in the Statewide striping policy.

Re-striping has been considered eligible for Federal aid funding since the early 1980's and would normally be classified as PM. The concept to remember is that each roadway element has a different service life. Causing a feature to be maintained beyond its original design is not cost-effective and generally does not provide the service intended. Re-striping according to local policy, cost-effective products, and the environmental effect, may occur several times in a pavement service life.

Not eligible - Localized or spot re-striping.


Eligible - Systematic replacement of signs in an area or road corridor based on retro-reflectivity measurements or a sign inventory/sign management system. New sign installation may be included in a sign replacement project if the new signs are recommended by the Traffic Safety Section.

Systematic replacement is eligible, however, new sign installation is not a Preventive Maintenance. This type of sign replacement program would also meet the criteria far rehabilitation/reconstruction

Not eligible - Replacing (random) single signs that have been damaged.


Eligible - Areawide or corridor wide culverts and/or end section replacement is eligible. Cleaning ditches to re-establish drainage in locations where standing water could weaken the roadway subgrade. Cleaning out storm drains would similarly be eligible.


Maintenance of landscaping is not eligible.

Maintenance of landscaping is not generally eligible, however, there could be some elements of roadsides that could be supported as PM

Bridge Work

Federal funds may be used to perform preventive maintenance on bridges included in the National Bridge Inventory that are not owned by a federal agency.


  1. Seismic retrofit Bridges must be on Alaska's seismic retrofit prioritization list.
  2. Scour countermeasures. Repair of spurs, spur dikes, rip-rap, and other river training structures used to minimize scour. Removal of significant amounts of debris upon concurrence of the Region or Headquarters Hydraulic Engineer.
  3. Crack sealing. Decks, girders, and substructure.
  4. Joint repair.
  5. Painting and repainting an entire bridge or areas essential for bridge performance. Painting smaller areas may be eligible as a part of a larger project to extend the life of the bridge.
  6. Deck overlays. Including repair of delaminated and spalled areas.
  7. Cleaning deck drains.
  8. Spalled concrete repair. Including repair to damaged superstructure due to bridge rail impacts.
  9. Bridge rail replacement or retrofit.

Bridge work NOT eligible

  1. Cleaning normal amounts of debris.
  2. Minor touch-up painting as a stand-alone task.

Under Bridge Work, it is unclear where the funding for preventive maintenance will come from, but some clarifications may be needed for using Highway Bridge Replacement and Rehabilitation Program (HBRRP) funding for these activities. The NHS Designation Act of 1995 expanded the eligibility for preventive maintenance activities to projects on the Federal aid systems. With this in mind. please consider the following:

1. Seismic Retrofit - retrofit of these bridges is also eligible under the HBRRP.
2. Scour Countermeasures - repair of spurs, spur dikes, riprap. and other river training structures used to minimize scour may be eligible for federal aid funding. To be eligible for funding using HBRRP funds, under the current law, the bridge would need to be eligible for replacement or rehabilitation.
3,4,7 are eligible as is.
5-6 may be eligible for PM or other federal aid funding 8. Spalled concrete repair as part of preparation for PM could be included in the cost of PM treatment. 9. Bridge rail replacement or retrofit, is eligible for federal aid funding using funds other than HBRRP.

The FHWA is currently reviewing its policies and the legislation pertaining to the HBRRP in an effort to provide the flexibility needed for the States to better manage and extend the useful service life of their bridges. An action is pending Chief Counsel's review at this time.

In general, the scope of a preventive maintenance project must be substantial in nature and of sufficient magnitude to warrant Federal-aid participation as a construction item. Preventive maintenance must he shown to be cost effective and should be drawn from a systematic or scheduled program. Preventive Maintenance differs from routine maintenance in that it is proactive rather than reactive.

On a final note, we have considered the issue of perpetual maintenance where the state has the responsibility to maintain a project orfacility forever. As the states completed the capital improvements of the 60's and 70's and the facilities met their anticipated service life, Congress recognized that the states would find it difficult to maintain federal aid projects in perpetuity. The introduction of I-3R and I-4R programs in the 70's and 80's provided for the rehabilitation, reconstruction, restoration, and resurfacing activities. By 1991, ISTEA allowed the flexibility of federal aid funds for cost-effective maintenance.

In Alaska's situation, with isolated discontinuous highways, it may not be cost-effective to provide preventive maintenance. Either rehabilitation or reconstruction may be the preferred alternative. If the State chooses to remove federal aid project from the system, there are provisions to revert ownership and responsibilities to the receiving governmental agency.

Preventive Maintenance Eligibility

With changing roles and program direction, the FHWA is currently in the process of reviewing eligibility requirements pertaining to transportation system preservation (TSP) activities including pavement, bridge and roadside and safety feature preventive maintenance. When completed, this process will offer guidance and recommendations to the division offices with regard to defining the nature and extent of these activities thus supporting determination of federal aid eligibility for such activities. This process will determine the need for policy (or regulation if needed) in the program area. In the interim, certain items are addressed herein as a response to Division Office inquires on eligibility of preventive maintenance activities for federal aid funding.

As an element of system preservation, pavement preservation is the sum of all activities undertaken to provide and maintain serviceable roadways including preserving the investment in the National Highway System, enhancing pavement performance, ensuring cost-effectiveness, extending pavement life, reducing user delays, and improving safety and mobility. Pavement preservation can be broken into three components: preventive maintenance, minor rehabilitation (non-structural), and some routine maintenance activities as seen in Figure 1.

{Graphic showing that the three components of Pavement Preservation are Minor Rehabilitation, Preventive Maintenance, and Routine Maintenance. Corrective Maintenance is off to the side.}

Figure 1: Components of Pavement Preservation

In the case of routine maintenance, the timing of application of the treatment determines whether activity is preventive or not. The preventive concept is to apply a treatment when the pavement is still in fair to good condition, generally before the occurrence and propagation of significant distresses. Pavement preservation activities do not include new pavement construction, reconstruction, major rehabilitation (structural), corrective or catastrophic maintenance.

As the focal component of pavement preservation, preventive maintenance is a strategy to apply cost-effective treatments to the surface of a structurally sound pavement. In 1997, the AASHTO Subcommittee on Maintenance established a task force to define the term "preventive maintenance." The task force made up of representatives from Nevada, Indiana, Kentucky, New York, Iowa, Kansas, and FHWA defined preventive maintenance as follows:

"Preventive maintenance is a planned strategy of cost effective treatments to an existing roadway system. and its appurtenances that preserves the system, retards future deterioration, and maintains or improves the functional condition of the system (without substantially increasing the structural capacity)" - AASHTO SCOH 1997.

To date, seven memoranda 'have been issued by FHWA; which pertain to preventive maintenance and its eligibility. The purpose of these memoranda was to provide guidance on approval of preventive maintenance projects and examples of work, which could be considered as preventive maintenance. The dates and subjects of these memoranda are as follows:

  • May 21, 1992 - " Intermodal Surface Transportation Efficiency Act (ISTEA) Implementation, Interstate Maintenance Program" (HNG-12)
  • July 27, 1992 - " Information: Preventive Maintenance" (HNG-10)
  • June 14, 1993 - " Information: Interstate Maintenance Program" (HNG-21)
  • October 12, 1993 - "Safety and Geometric Considerations for InterstateMaintenarice Project's" (HHS-21/HNG-21)
  • March 21,1996 - " Preventive Maintenance Revision to 23 U.S.C. 116" (HNG-21)
  • June 18, 1997 - " Information: Transportation System Preservation (TSP)" (HNG-21)
  • October 30, 1998 - " Information: Implementation TEA-21 Interstate Maintenance Guidelines" (HNG-21)

The importance of maintaining our highway infrastructure was first recognized in the 1978 Surface Transportation Act (23 U.S.C. 109(m) and 119(b)) and its emphasis on Interstate Maintenance, The 1995 NQI " National Highway User Survey" indicated many highway users were dissatisfied with the effectiveness of pavement conditions and maintenance response time on our highways. The follow-up survey conducted by the National Partnership for Highway Quality (NPHQ) (formerly NQI) in 2000 shows 65 percent of highway travelers are satisfied with the major highways they travel the most. This represents a 15 percent increase since 1995. One should also note that an increase in dissatisfaction of six percent to a 20 percent level was identified with traffic congestion showing the most critical area for improvement.

Although not as clearly defined as pavement activities, preventive maintenance concepts are also valid for other highway infrastructure assets. Bridges, safety hardware, signage and other appurtenances, and in some cases landscaping can be a contributing component (i.e. living wind screens, ditch and drainage, and erosion abatement). This list, of course, is not all inclusive. The function and contribution to operations and performance must be considered.

Pavement Surface (PCC, asphalt, earth)

Eligible - Preservation activities such as chip seals, fog seals, slurry seals, surface seals, microsurfacing, non-structural thin lift overlays (<2"), non-structural thin lifts are usually limited to 1-1/2" profile milling, crack sealing, PCC joint resealing, spall repair, dowel bar retrofit, full and partial depth repair, and diamond grinding are considered eligible for federal aid funding if they are performed as part of a network wide, cost effective, pavement preservation strategy. Such a strategy will be proactive in nature and can be demonstrated as a cost effective means of extending the life of the roadway. For lighter traffic volumes (generally 150-500 vpd), stabilization of earth/aggregate roadways can be eligible if the activity will prevent deterioration of the roadbed and aggregate surfacing and maintain safe driving conditions.

Not eligible - Maintenance activities, which are considered reactive in nature. Such activities include reactive maintenance (i.e. pothole patching), catastrophic maintenance, and routine maintenance applied to roadways to correct random or isolated existing damage/distresses. Occasional reworking roadbed to correct limited or isolated wash boarding or rutting is not eligible. The length of the roadway section is also a consideration. Spot repairs and/or isolated activities are not eligible for federal aid funding, Localized roadway repair due to permafrost damage is not considered a preventive maintenance activity but is eligible for federal participation as a roadway rehabilitation need, Activities such as new construction, reconstruction, structural (both increased load and/or traffic capability) rehabilitation, and repair activities associated with subbase, subgrade, and/or major drainage deficiencies should be considered for regular federal-aid funding.

Guardrail/Safety Barriers/Impact Attenuators

Eligible - a network/area wide upgrading program (end treatments, panels, and hardware) to current standards. This would be considered as maintaining functional safety standards. In this case either preventive maintenance or regular program dollars would be eligible.

Not eligible - repair/replacement due to collision damage, snowplow damage, and overall deterioration. Isolated and/or spot repairs/replacement not part of a network/area wide upgrade program would be considered routine maintenance.


Eligible - a network/area wide lighting upgrade/enhancement program that can be demonstrated as being cost effective and energy efficient. Components eligible include poles, light fixtures, luminaries, and associated hardware. It is conceivable that traffic signals can be re-lamped on a set cycle to prevent loss of use. Also consider adding network/area-wide interconnects.

Not eligible - replacement of isolated or random burned out/damaged bulbs or luminaries. Replacement/repair of light poles, fixtures due to collision damage or deterioration. Isolated upgrades not part of a network/area wide program would be considered as routine maintenance. Initial installation of new equipment.

Pavement Striping

Eligible - A network wide/area wide re-striping program that is designated to maintain the continuous overall level of effectiveness/safety of the pavement marking in a cost effective manner. The cost effectiveness of using a specific pavement marking material must be demonstrated. Generally, new striping will be included in a surface treatment project and will eligible.

Not eligible - Annual and/or routine striping, new striping applied in a routine cycle without consideration of performance durability and overall cost effectiveness.


Eligible - Upgrading of existing signs to current standards on a network/area wide level.

Not eligible - Replacement/repairing of signs due to vandalism and damage not part of a network/area wide upgrade program (i.e. isolated instances).


The use of Highway Bridge Replacement and Rehabilitation funds for preventive maintenance is currently not provided by the Section 144 of the law. Funding sources currently available for preventive maintenance activities on bridges include the IM funds, NHS funds, and STP funds.

The FHWA supports preventive maintenance as a method to maintain the structural integrity of bridges and extend service lives of various bridge elements. Bridge preventive maintenance will also prolong the period before a bridge would deteriorate to a condition that will be determined by inspection to be deficient. A change in legislation will be required to allow preventive maintenance to be accomplished with HBRRP funds. This issue is under review and consideration by the FHWA.

Preventive maintenance activities for bridges include work that prevents accelerated deterioration (cleaning and painting, deck drain and scupper cleaning, cleaning and repair of joints, bearings and hinge joints). Surface treatments that preserve the existing bridge deck overlays. These work items extend the service life of the various elements of the structure. NHS, IM, and STP funds can be used for these preventive maintenance activities. There is flexibility in determining the most cost-effective method of extending the service life of the bridge. A comprehensive bridge management system (BMS) can help identify those methods. The BMS is eligible for HBRRP funds.

Updated: 06/27/2017
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