**A review of our infrastructure shows that there are only a small
number of highway tunnels located in New Jersey. So it is unlikely that
the adoption of a new program requiring the inspection of highway
tunnels would result in a significant new effort for New Jersey
considering that we already perform periodic inspections. In particular,
the Route 29 tunnel in Trenton and the Route 18 Sports Park structures
would likely be included in the program along with many older, small
tunnel structures in northern New Jersey under railroad grades.**

**Our comments (in bold) on the specific items listed in the Federal
Register for the NTIS are as follows:**

1.  Definition of "Tunnel':

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A.  Should the definition of a 'tunnel' contain a minimum length
    requirement? **--No**

B.  Should the definition of a 'tunnel' contain a requirement other than
    tunnel length?---**It would be a good idea to define the difference
    between a 'bridge' and a 'tunnel' (i.e., construction method,
    etc.).**

C.  Tunnel definitions---**We agree with the AASHTO definition of
    tunnel.**

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1.  Inspection Procedures:

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A.  Should the NTIS adopt the inspection techniques and standards in the
    Highway and Rail Tunnel Inspection Manual?**---The NTIS provides a
    good starting point for the development of specific requirements for
    the inspection of highway tunnels.**

B.  What additional sources of inspection standards should the FHWA
    consider?**---We lack any other specific standards and are unaware
    of any additional standards that would be useful.**

C.  Should inspections include evaluation of emergency response and
    non-emergency operational procedures?**---No. Security (in
    particular) and operational checks would be conducted at short
    frequencies compared to the other system checks. We feel that
    security and operational issues should be specified as items that
    require the owner's attention and that methodology be provided.
    However, actually tracking these evaluations and checks, where
    security exists, would be voluminous.**

D.  Are there any special inspection procedures for new tunnels that
    should be included in inspection manuals for all new tunnels?**---No
    comment.**

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1.  Frequency and Types of Inspections:

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A.  What tunnel elements and systems should be inspected
    routinely?---**Structural, Mechanical, Electrical & Ventilation
    Systems. Security system should be handled in a similar manner as
    security is handled elsewhere in a transportation system, although
    security in a large tunnel would obviously be a high priority item
    and very frequent checks would be in order.**

B.  What inspection frequency should be established for these elements
    and systems?**---We feel that the structural system should be
    inspected every two years (like bridges). The other systems should
    be inspected either more or less frequently depending on the
    specific situation---possibly this should be the prerogative of the
    owner.**

C.  Should a minimum frequency for tunnel inspection be
    established?**---Two years for the structural system inspection.**

D.  Is there a need to identify various types of inspections?**---Yes**
    If so, what types of inspections should be defined?**---Initial,
    Routine, Special, In-Depth & Damage inspections---as in bridge
    inspections.**

E.  Should the frequency of each type of inspection vary according to
    the type of inspection?**---Yes---as in bridge inspections.**

F.  Should we establish a risk-based frequency to account for the
    complexity of each tunnel?**---Yes, due to the wide differences
    between tunnels.**

G.  What factors (e.g., age, traffic, length, ventilation, urban or
    rural location) should be included in a risk-based frequency
    inspection system?**---Age, Condition, Traffic, Detour Length,
    Presence of Mechanical or Ventilation Systems, Design Type, Tunnel
    Length, Submerged (or above water level), Presence of Security
    Systems, etc.**

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1.  Equipment and System Inspection:

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A.  Mechanical Inspection: **Yes**

B.  Structural Inspection: **Yes**

C.  Safety Inspection: **Yes**

D.  Security Inspection: **Yes---although due to the number of such
    checks required for tunnels with security systems (like the Lincoln
    Tunnel), tracking the checks in the NTIS may not be realistic.
    Possibly, the system should just indicate the frequency of such
    checks rather than actually tracking the dates/findings of the
    checks.**

E.  Electrical Inspection: **Yes**

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1.  Qualifications and Required Training of Inspectors:

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A.  Should the qualification requirements for transit tunnel inspectors
    contained in the Highway and Rail Transit Tunnel Inspection Manual
    be adopted as the qualifications required for Federal-aid highway
    tunnel inspectors?**---No** Are the qualifications in the Highway
    and Rail Transit Tunnel Inspection Manual sufficiently specific for
    all tunnel elements and systems?**---No **

B.  What education and training should be required for tunnel
    inspectors?**---We should use the NBIS as an example and specify
    appropriately. ** Should the NTIS incorporate a requirement for
    periodic training for tunnel inspectors?**---Yes. In particular, we
    feel that a basic training course on the design and inspection of
    tunnels would bring staff that has experience with other related
    inspections quickly up-to-speed on tunnel inspections.** **Follow-up
    or refresher training would keep staff abreast of new developments
    or change that has occurred. We feel that training similar to what
    NHI provides for bridge inspections should be provided for
    tunnels.**

C.  What experience should be required for tunnel inspectors?**---The
    experience should relate to the type of systems being inspected.
    Structural inspection experience for the structural inspection team;
    Mechanical system inspection experience for the mechanical system
    inspection team; Etc.** **However, we would be concerned if specific
    training in tunnel design is mandatory because the pool of potential
    inspectors with this particular expertise is very thin and would
    result in higher costs than is felt necessary. **Should there be
    multiple levels of qualifications depending upon the role of the
    team member (i.e., leader, inspector) and the type of
    inspection?**---No. We feel that only the Program Manager's and Team
    Leader's qualifications should be specified as in the NBIS**

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1.  Recordkeeping:

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A.  Should States be required to keep records of all highway tunnel
    inspections performed within the State?**---No, the owner should be
    required to keep the records.** If not, where and with whom should
    the inspection records reside?**---The owner.**

B.  Are inspection record requirements such as those contained in the
    Highway and Rail Transit Tunnel Inspection Manual sufficient for the
    NTIS?**---We feel that the Manual provides a good starting point.**

C.  For how long should tunnel inspection records be maintained?**---The
    same as for bridges.**

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1.  Rating:

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A.  Should the NTIS incorporate a condition-based rating system for
    Federal-aid highway tunnels, under which the tunnels in the best
    condition receive a high rating and the tunnels in the poorest
    condition receive a low rating?**---Yes, since bridge inspectors are
    familiar with this system and they would likely be the same people
    conducting structural inspections of tunnels.**

B.  Should a tunnel rating system be the basis for possible funding
    decisions?**---If a Federal program is being initiated for tunnel
    repair and reconstruction (similar to bridges), absolutely.**

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1.  National Tunnel Inventory database:

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A.  What tunnel data elements should be collected for all Federal-aid
    highway tunnels (e.g., tunnel name, age, length, finishes, width,
    height, number of lanes, ventilation, truck traffic, automobile
    traffic)?**---We recommend using the NBI as a starting point for
    determining what data should be collected (Identification Data,
    Classification Data, Structure Data, Condition/Appraisal Data,
    Inspection Data, etc.) and adding specific information for tunnels
    that is not present on most bridges.**

B.  How often should data be collected and reported?**---Data should be
    collected at a central State repository as inspections occur
    (similar to the NBI). **

C.  Should the data be reported to the FHWA?**---Not required unless a
    program similar to HBRRP is proposed.**

D.  Should a tunnel be identified using a tunnel inventory number (TIN)
    in a manner similar to how bridges are identified under the
    NBIS?**---Yes**

E.  What criteria should be used to assign a TIN?**---The owner should
    determine as they do for bridges.**

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1.  Organization of Inspection Teams:

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A.  How should the inspection teams be organized? **Separate inspection
    teams for each** **system inspection should be established (i.e.,
    Structural, Mechanical, Electrical, etc.). This would allow for each
    team to operate independently to perform their specific function
    rather than trying to establish a large, multi-disciplinary team.
    This organization would also allow for the inspection cycles of the
    various disciplinary teams to vary.**

B.  Should inspection teams be established with differing levels of
    responsibility? **As above, we feel that separate inspection teams
    by discipline should be established and each team would be
    responsible for their particular discipline. The Program Manager
    would be tasked with overall responsibility of the inspection
    program.**

C.  Should one person on the team have overall responsibility for the
    program? **No,** **the overall responsibility should rest with the
    Program Manager. The Team Leaders should have a responsibility for
    their specific discipline.**

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1.  Technical References: What technical publications, if any, should be
    incorporated by reference? **No comment.**

2.  Quality Control/Quality Assurance (QC/QA): Should QC/QA procedures
    similar to the procedures required under the NBIS be implemented for
    the NTIS? **Yes**

3.  Cost of Inspections: The FHWA requests information regarding the
    costs associated with tunnel inspections, particularly the typical
    inspections costs per linear foot of tunnel. **No comment---no
    information available.**

4.  Tunnel Repairs: The FHWA requests information associated with tunnel
    rehabilitation projects (e.g., costs of repairs, dates of work,
    scope of work). **No comment---no information available.**

5.  Research: The FHWA and others have conducted extensive research
    related to tunnel design, construction, rehabilitation, and
    inspection. The following is a list of research projects related to
    tunnel safety that either have been conducted or are ongoing. We
    welcome information regarding other existing or ongoing research
    related to tunnel inspections. What additional research should be
    undertaken? **No comment.**