November 9, 2005

Mr. Tim Arnade, Safe Routes to School Program Manager
Federal Highway Administration
HAS-20, Room 3407
400 Seventh Street, SW
Washington, DC 20590

Re: Infrastructure and Non-Infrastructure Activities

Dear Mr. Arnade:

Thank you for asking the Safe Routes to School National Partnership to provide additional information on the SAFETEA-LU requirement for Safe Routes to School infrastructure and non-infrastructure activities.

The Safe Routes to School National Partnership is a growing coalition of national, state and local organizations, agencies and businesses that are working to advance the Safe Routes to School movement nationwide and in all 50 states. Many of the organizations that are members of the Safe Routes to School National Partnership have been running successful Safe Routes to School programs at local and state levels for several years. We hope that our experience can help you to shape the guidelines for the federal program in a manner that will be most useful for the intended purpose of the program.

As you know, the federal Safe Routes to School Program is designed to enable and encourage school children to walk and bicycle to school on safe routes. The legislation that establishes the program states that it is to include two distinct components: infrastructure projects and non-infrastructure related activities. It was the clear intent of Congress for non-infrastructure activities to be an important part of the Safe Routes to School program.

The Safe Routes to School National Partnership strongly encourages FHWA to assist state DOTs in understanding the importance of the non-infrastructure activities. We also urge FHWA to provide DOTs with recommended methods to ensure that both infrastructure and non-infrastructure initiatives are effective, and achieve the outcomes desired by the Federal program. Infrastructure projects are commonly understood as engineering projects, while non-infrastructure activities generally refer to education, encouragement, and enforcement. Both types of activities require evaluation activities.

In the sections that follow, we have identified opportunities to maximize outcomes and provided examples, models and concerns based on our extensive collective experience assisting Safe Routes to School initiatives in many states over a period of years.

Opportunities to Maximize Outcomes

There is already an incredible demand for Safe Routes to School programs throughout the United States. The Safe Routes to School National Partnership would like to work with FHWA and State DOTs to stretch the $612 million in federal funds (FY05-09) as far as possible. As such, we believe that it will best serve states and communities throughout the United States if the infrastructure and non-infrastructure grants can be separated. Opportunities for benefits resulting from this process include the following:

    1. Reaching More Students: Allowing for non-infrastructure activities to compete separately for funding will enable large-scale applications of education and encouragement models which can include interventions at numerous schools within a city, county, region, or state. Through this model, FHWA and State DOTs can exponentially expand the number of students who are reached by the federal Safe Routes to School program.
    2. Creating Ongoing Programs: Through providing multi-year grants to non-profits, cities, counties or other entities to manage non-infrastructure activities, ongoing programs can be offered in schools within a city, county, region, or state. Partnerships are developed with schools, public works departments, law enforcement, businesses, non-profits, parents, students, and other stakeholders. The ongoing nature of the education and encouragement programs are instrumental for improving safety, shifting mode share, and developing a culture that supports walking and bicycling to schools.
    3. Nurturing Community Involvement and the Selection of Infrastructure Projects: Non-infrastructure activities often result in forming “Safe Routes to School Teams” and “Task Forces” which cover individual schools and/or entire cities. By bringing together collaborative partners, the non-infrastructure process can also lead to recommendations for infrastructure projects which have the most community support. Some of these infrastructure projects may be funded by the federal Safe Routes to School program, and in some instances, local cities may decide to use general funds for small fixes that may be remedied through paint, signage or improved law enforcement. The process of creating “Safe Routes to School Teams” results in local ownership for the program by the school, the municipality, parents, students, and other stakeholders.

Examples of Successful Non-Infrastructure Activities

The following examples from several states illustrate non-infrastructure activities (i.e., education, encouragement and enforcement) which encourage and enable walking and biking to school. These are the types of activities that we hope to see funded through the non-infrastructure activities in the federal Safe Routes to School (SR2S) program.


Statewide Non-Infrastructure Program
dIn the year 2000, the California Department of Health Services received a grant from the California Office of Traffic Safety (402 funds) to create non-infrastructure Safe Routes to Schools programs. The Department of Health Services developed a call for applications for mini-grants and as a result of a competitive process, 10 different communities received grants of $25,000 each. Some of the communities that received the grants went on to create full Safe Routes to School programs, including Marin County and Santa Barbara.

Marin County
Marin County’s program began with $25,000 from the California Department of Health Services and a $50,000 cooperative agreement to run a pilot program through the National Highway Traffic Safety Administration. The NHTSA pilot was run by a non-profit in nine schools throughout the County. The Program Director for Safe Routes to School developed “teams” of volunteers at each school which ran education and encouragement programs. The Safe Routes “teams” also worked with public works departments to identify safety issues along the routes to schools, and when consensus was reached on priority projects, infrastructure funding applications were prepared for the California DOT competitive capital program, which has dispersed $22 million/year statewide for Safe Routes infrastructure since the year 2000. Marin schools have received capital grants of over $2 million from this fund as a result of this effort.

The Marin pilot program was so successful that the County of Marin eventually became the lead agency for the program, and sought funding to make the program permanent. In November 2004, voters in Marin County passed a ½ cent sales tax for multiple transportation purposes, including $36 million over the next 20 years for Safe Routes to Schools. The Safe Routes to Schools funding is being used for three programs: Education and Encouragement programs, the Crossing Guard program, and an Infrastructure program. Each program has a separate bidding process and guidelines to ensure that the desired outcomes of each program are achieved. The Education and Encouragement program is the overarching program; and each program interacts with the others. Consultants for the Education and Encouragement programs provide comments and feedback to consultants working with the other programs. The Marin County program is currently serving 40 schools with its Education and Encouragement program.

Santa Barbara
In Santa Barbara a non-profit organization manages the Safe Routes to School program in 16 schools on a $35,000 annual budget. A non-profit staff member coordinates the efforts of 20 agency and community partners, including the Santa Barbara Bicycle Coalition, the PTA Safety Committee, various government and law enforcement agencies, Traffic Solutions and the Diabetes Resource Center. They have developed a school zone safety package, a public awareness program, including two bilingual safety videos, and an education and safety-training program. The program also distributes low-cost bicycle helmets, free to low-income children.


The KidsWalk to School program, which is led by a non-profit organization, has been funded by foundation grants and federal transportation funds since 1999. The program emphasizes Walk on Friday events, increased traffic enforcement, low-cost safety improvements, and uses International Walk to School Day as a recruiting tool to encourage schools to get involved in the year-round program. The program currently serves eight schools on a year-round basis and has led to dramatic changes in mode share at elementary schools in Atlanta. At Mary Lin Elementary School, for example, where only one parent walked her children to school in 1999, 90 students are now walking to school on a daily basis. The change in mode share has resulted in increased safety and decreased traffic congestion. The non-profit organization conducts walking audits and organizes charrettes to help the community reach consensus on desired safety improvements on routes to school. The non-profit is also partnering with a leading manufacturer of speed camera devices and the media to bring attention to speeding in school zones. The non-profit has also created an online toolkit which will facilitate expanding the program throughout the region. The MPO for metro Atlanta plans to gives priority for funding sidewalks to schools that participate in the Walk-to-School encouragement and education program.

Another example is the Metro Atlanta Safe Routes to School Program, which is the first comprehensive program to promote both walking and biking to school in the state of Georgia. The four-year program was funded with a $400,000 grant from the Georgia Department of Transportation in association with the Federal Highway Administration. A non-profit organization is carrying out the project in four schools. The development of strong relationships as an outcome of offering education and encouragement programs in the schools is an integral component of success. Staff at one school worked closely with parents and the Parent/Teacher Association (i.e., attended meetings, identified a parent volunteer and assisted volunteers) to hold monthly Walk and Roll school events. These events promote walking and biking to school on a regular basis, educate school students and parents on the health benefits of walking and biking, and are expected to continue due to ownership by the PTA. At another school with a large Hispanic population, non-profit staff built relationships with parents which led to a Mom’s Safe Routes to School Club. In other schools, Safe Routes staff have developed relationships with principals which have led to active principal involvement as leaders of Walking School Buses and Bike Trains. The involvement of the principals is in turn influencing parents and students and contributing to increased safety and mode shift.


The Michigan Department of Transportation funded a non-profit organization to assist Michigan elementary schools with Safe Routes to School team start-up, resources and procedures to complete the 5 Es (i.e., Michigan SRTS Toolkit), ongoing support (e.g., website, monthly newsletter, training, survey design and data collection and analysis) and support to successfully sustain SRTS over time. The non-profit also oversees the quarterly meetings of the statewide SRTS coalition of 25 active member agencies, departments and organizations. Objectives for the non-profit were developed by a multi-disciplinary steering committee composed of representatives from the DOT, Department of Community Health, Department of Education, Michigan State University Extension Service, MSU Department of Community Resources, League of Michigan Bicyclists, Rails Trails Conservancy/Michigan Trails and Greenways Alliance, and Safe Kids Coalition and an active state coalition of 25 meets quarterly, including representatives from SRTS school teams.

Examples of SRTS local activities and outcomes in Michigan include:

Non-profit staff provided training and assistance to the Belmont Elementary School team leader, who held a Safe Routes to School kick-off assembly using resources provided by the non-profit. Students learned of the health benefits of physical activity during the assembly. The school principal reports that the number of students arriving at school by foot or bike increased dramatically as a result of the assembly and newsletters/promotion undertaken by the school. The school SRTS team also has an action plan objective to connect the school to an existing trail that students can then use to travel to/from school by foot or bike. The Michigan non-profit assisted Rails-to-Trails Conservancy staff with the development of this actionable step.

Non-profit staff assisted the multi-cultural community at Washington Elementary to start a Safe Routes to School initiative by providing Spanish translations of an information flyer, school brochure and parent survey. Staff also assisted with a presentation to the School Board, building a relationship with the Flint Police Department, and with developing a strong tie to a local foundation that will provide long-term community support for traffic reduction and control in this community of high-unemployment.

Building Local Multi-Disciplinary Teams
Multi-disciplinary local teams are essential to effective SRTS initiatives. The non-profit, through training, phone and e-mail contact, attending local team meetings, and coaching team leaders, assists with local team development. For example, law enforcement agencies are essential partners in Safe Routes to School efforts. In Pontiac, Michigan, the SRTS champion was a strong and passionate voice for safe routes; however, she did not initially understand that police officers could not constantly patrol school routes and she did not understand the importance of creating a win-win perspective and outcome. With non-profit staff coaching, the Webster Elementary School Team in Pontiac now has the strong support of local law enforcement officers and school community members report a reduction in the presence of crime due to increased police presence.

Statewide Walk to School Day
As part of encouraging walking to school and to increase awareness about the benefits of physical activity, non-profit staff provided resources for Walk to School Day (e.g., SR2S stickers, customizable flyer, ideas to adapt Walk to School Day to local conditions) to 223 elementary schools in Michigan, reaching over 85,000 students. Hundreds of parents and community members also learned of the health and traffic reduction benefits that are associated with increased walking and biking to school.


A non-profit organization receives funds from the Oregon Department of Transportation to provide technical services to interested communities on Safe Routes to School programs. The non-profit provides resources and information, trainings, site visits, and ongoing e-mail and phone support. The non-profit also brings specialized knowledge of marketing, planning, and plan development to aid Safe Routes to School communities as they launch and sustain local efforts. In addition, the non-profit works closely with the City of Portland to help develop and oversee their SRTS Program, including running education and encouragement activities citywide.


Statewide Non-Infrastructure Program
Safe Routes to School (SR2S) was the major component of the Matthew Brown Act that was passed in 2001 by the 77th Texas Legislature. The program is infrastructure only and had no committed source of funds.

In 2003, a Call for Projects was issued by the Texas Department of Transportation (TxDOT) funded at $3 million from the State Transportation Enhancement Program account. Demand was extraordinary. Two hundred fifty-nine applications requesting $45 million were submitted. Of those, 27 projects were selected for a total cost of $5 million in both federal pass-through and local matching funds. While the program has been well received by the citizens of Texas, elected officials and TxDOT staff, there has not been another call for projects. All the interested parties have been patiently waiting for the federal transportation bill to pass and FHWA Guidance before issuing another call.

Statewide Non-Infrastructure Program
In 1998, TxDOT awarded a 402 Traffic Safety grant to a non-profit, based on the organization’s successful SuperCyclist Curriculum. The non-profit has been re-awarded a similar 402 grant for seven consecutive years. While the program goals and name have varied somewhat from year to year, the overall results have been built upon each previous year’s successes. The 402 re-imbursement grant for approximately $300,000 per year has allowed the non-profit to teach bicycle safety to more than 4,500 elementary 4th and 5th grade physical education teachers. Many of those teachers have reported back that they have taught up to 500 children each per year. Estimates are that more than 400,000 Texas 4th and 5th grader students have received SuperCyclist bicycle/pedestrian traffic safety training.

The grant has also made it possible for the non-profit field instructors to teach faculty at 14 Texas universities. The result is that more than 1,500 future teachers have been certified to teach the Texas SuperCyclist Curriculum, the nationally-recognized curriculum that has been developed and revised with input and funding from the Texas Department of Transportation, the Texas Department of Public Safety (TxDPS) and the National Highway Traffic Safety Administration (NHTSA).

Based upon the experience, institutional relationships and staff acquired during the course of the SuperCyclist teacher training program the non-profit received a Carol M. White Physical Education Program Grant from the Texas Education Agency Office of Safe and Drug Free Schools. The grant commenced in October 2004 and targets 300 schools in 33 school districts in a region of Texas that is slightly larger than the state of Louisiana. The grant funds the BikeTexas Safe Routes to School Program (BikeTexas SR2S). BikeTexas SR2S combines the Texas SuperCyclist Curriculum with a large-scale “encouragement” program to promote elementary school children to bike and walk to school appropriate to their ages. BikeTexas SR2S staff (local outreach coordinators) work with a pool of up to 30 schools each to help the school community increase the number of children biking and walking to school. Local outreach coordinators train parent volunteers, called “Team Leaders” to champion the efforts at their own child’s school. The local outreach coordinators provide the tools and help identify the real or imagined obstacles that prevent the children from biking and walking to school. Each school community will prepare their own applications for “infrastructure” with the assistance of local outreach coordinators. While the infrastructure funds will go to schools and counties, experience has shown that informed school and neighborhood level involvement in the infrastructure application process can improve the quality of the applications.

State Models Illustrating Structural Separation of Infrastructure and Non-Infrastructure Activities

As illustrated through the examples above, there can be tremendous benefits associated with large-scale applications of Safe Routes to School non-infrastructure activities. In order to encourage and facilitate these types of large-scale applications, it is necessary to separate the infrastructure and non-infrastructure activities.

The National Partnership urges FHWA to strongly recommend to State DOTs that they separate the grant application processes for infrastructure and non-infrastructure projects and activities. This is the best way to preserve the distinctly different, important, purposes of each program, and to ensure adequate expertise to award, monitor and evaluate the two distinct Federal Program components. We believe that separating these pots of funding would best facilitate achieving the federal program purpose stated in the legislation. We offer the following recommendations for how states could accomplish this:

  1. Separate Application Forms: States could develop separate application forms and evaluation criteria for infrastructure and non-infrastructure activities to ensure that 10-30% of funds are used for non-infrastructure activities that affect behavior change. This arrangement will also make it easier for the State DOT to account for the percentage of funds that were spent on non-infrastructure activities verses infrastructure activities.
  2. Criteria for Application Review: States could establish and utilize appropriately distinct criteria when reviewing applications and making awards for infrastructure verses non-infrastructure activities, and when evaluating outcomes.
  3. Consider Best Practices Models When Allocating the 10-30% for Non-Infrastructure: States can consider best-practices from other regions for funding allocations. Below are several examples for how the non-infrastructure funds could be allocated by a State DOT with ease of administration:
    • The State DOT could run distinct competitive grant application processes for both the infrastructure and non-infrastructure pots of funding. Non-infrastructure grant applications should include questions related to goals, strategies, collaborative partners, marketing, and the approach for getting the educational, encouragement, and enforcement program elements adopted by the targeted school systems. Grants for non-infrastructure activities should be made to organizations and entities that have experience in bicycle and pedestrian education and encouragement. Schools and cities should be permitted to submit grant applications for both the infrastructure and non-infrastructure activities, understanding that the city may administer the infrastructure grant whereas a non-profit may administer the non-infrastructure activities on a city-wide, county-wide or state-wide scale.
    • The State DOT could provide funding to another state-level department (e.g. the health department, the governor’s office on traffic safety, or a bicycle and pedestrian safety department within DOT) to administer the grant applications and evaluation components for the non-infrastructure requirements. This entity would then be responsible for reporting on the results to the State DOT.
    • The State DOT could provide the non-infrastructure funding in a single grant to a state-level entity (e.g. non-profit organization) with demonstrated success in providing leadership and behavior-related services to state, regional, and local groups including schools and children. The non-profit would be responsible for running the non-infrastructure component of the program and would be responsible for adhering to the evaluation requirements stipulated by the DOT. It may be necessary or important for the non-profit to allow for mini-grants to be made available for specific activities related to the eligible activities under section 1404.

We have attached as Appendix A, a series of flow charts from different states, as models that illustrate how separating the infrastructure and non-infrastructure SR2S funding can provide for flexibility, ease of administration, and accuracy of accounting.

Concerns Regarding the Overall Impact of Ineffective or Incomplete Non-infrastructure Activities

The Safe Routes to School National Partnership offers these concerns in support of our recommendation that state DOTs be asked to clearly separate infrastructure and non-infrastructure proposals and awards, and be accountable for doing so. We believe that this is absolutely essential for the overall success of the Federal SR2S Program. We believe that this separation will lead to more effective non-infrastructure activities and avoid the following scenarios.

  1. Low capacity and interest: State DOTs and local agencies that build and maintain roads are expert in material construction projects and utilizing guidelines and criteria for such projects. While state DOTs have had the authority for many years to undertake non-infrastructure (i.e., non-construction) projects, we observe little interest or enthusiasm for these kinds of projects as indicated by the low level of allocation to the bike/ped safety program category in the Transportation Enhancements program since 1997. In addition, non-infrastructure activities, as with infrastructure projects, are effective when managed by knowledgeable and skilled practitioners. This knowledge and expertise is not likely to be found in most state DOTs.
  2. Small number of projects: If awards for applications combine infrastructure and non-infrastructure, with a 10-30% requirement for non-infrastructure, it is possible that awards will be determined based upon the infrastructure project, (i.e., the more costly project). This may result in fewer overall projects in any given state. For example, the many states that receive only $1 million/year for Safe Routes to School will only be able to reach a few schools each year if this scenario unfolds.
  3. Type of non-infrastructure activities that may be funded: Many of the project applications for infrastructure funds will be city departments of public works. Due to the requirement that 10-30% of the funds be spent on non-infrastructure activities, public works departments (which will largely have limited experience working with non-infrastructure activities) will likely look to the easiest possible way to fulfill the non-infrastructure requirement. As such, many Safe Routes to School projects may over-utilize law enforcement as their main or sole non-infrastructure activity, rather than working to create broad-based partnerships to affect safety, mode shift and traffic reduction.
  4. Non-infrastructure activities may not be cost-effective: Should some public works departments try to include education and encouragement models at the school where they are creating infrastructure improvements, the education and encouragement will likely only last for the length of time that the grant is in effect. Studies have shown that education and encouragement models need repeated applications to be effective in changing behavior. In addition, non-infrastructure activities applied only to one school--versus a school district, region, or state--are not an efficient use of resources and economy of scale is lost. However, if separate awards and funding mechanisms are provided, entities with expertise and that serve larger geographic areas can become involved.
  5. Cost-overruns on infrastructure projects: If the infrastructure and non-infrastructure funds are combined, non-infrastructure activities may be squeezed or diminished due to potential cost-overruns associated with the infrastructure project. Safe Routes to School is based on building partnerships and collaborations, but due to fears about cost overruns, many local road authorities will chose to not begin the non-infrastructure activities until their infrastructure project is completed, and the non-infrastructure activities could become an “after thought” rather than an important component of ongoing behavior change.
  6. Evaluation of grant proposals and program effectiveness: The evaluation of grant proposals for infrastructure and non-infrastructure projects, and the evaluation of the success of infrastructure and non-infrastructure interventions require two separate and distinct types of criteria. We are concerned that if the programs are lumped together that the non-infrastructure activities will not be evaluated properly.

In conclusion, the Safe Routes to School National Partnership feels that the separation of infrastructure and non-infrastructure funding is a critical component for achieving the outcomes for the Federal Safe Routes to School Program as outlined in of section 1404.

We believe that: a) the reach of the program; b) its success in encouraging and enabling school children to walk and bicycle to school, using safe routes, in order to receive the health benefits of regular physical activity; and c) the ability of state DOTs to ensure equitable, effective and efficient use of federal funds requires strong guidance on this matter.

Thank you for your careful attention to the requirement for 10-30% of 1404 funds to be spent on non-infrastructure activities each year, in each state. Please let me know if you have questions about our recommendations, or would like to discuss this further. The Safe Routes to School National Partnership is eager to assist FHWA with ensuring success for this new federal program which has the promise to change the habits of an entire generation of school children.


Deb Hubsmith, Coordinator
Safe Routes to School National Partnership

Cc: Congressman James Oberstar
Stephanie Manning, House Transportation and Infrastructure Committee Staff

Attached: Sample draft flow charts for the separation of infrastructure and non-infrastructure activities in the following states: