Craig Fink, P.E.

County Engineer

DeWitt County Highway Department

R.R. 2 Box 82P

Clinton, IL 61727-9584

I have the following comments regarding the Advanced Notice of Proposed
Rulemaking on the National Bridge Inspection Standards (NBIS) as
solicited by the FHWA on docket number FHWA-2001-8954 as published in
the Federal Register: September 26, 2001 (Volume 66, Number 187).

**[APPLICATION OF STANDARDS]{.underline}**

The FHWA should [NOT]{.underline} develop it\'s own definition of a
bridge for inspection and reporting. This would create unnecessary
additional work and associated costs for all levels of government
involved in surface transportation where there has not been a sufficient
demonstrated need for such change.

The FHWA definition should [NOT]{.underline} change the way a bridge
length is determined or what the minimum bridge length should be for
reporting purposes as this would create unnecessary additional work and
associated costs for all levels of government involved in surface
transportation where there has not been a sufficient demonstrated need
for such change. The FHWA may desire to clarify the way the existing
definition of bridge length is applied to certain structures where there
is widespread inconsistency in application.

The FHWA may desire to allow structures of less than the minimum bridge
length to be eligible for HBRRP funds in the HBRRP rules.

**[INSPECTION PROCEDURES]{.underline}**

The FHWA should allow greater intervals between underwater inspections
where safety is not impacted which would reduce the work and associated
costs for all levels of government involved in surface transportation.

**[FREQUENCY OF INSPECTIONS]{.underline}**

The interval of inspection for bridges which are stable for scour, which
have no known defects and are operating within their design parameters
should be allowed to have a 10-year inspection cycle, subject to a
change in any the above conditions or catastrophic events which would
warrant earlier inspection.

The level of service of a bridge should be taken into account for any
inspection requirements. A bridge on a township road serving only
farmland should not be held to the same inspection frequency as an
interstate bridge, for example, if all other factors are equal between
the two bridges.

**[QUALIFICATION OF PERSONNEL]{.underline}**

A registered Professional Engineer who is in charge of inspection and
reporting should [NOT]{.underline} be subjected to any NBIS training
requirements. A registered Professional Engineer is already required to
determine whether he/she is qualified to act in certain capacities.

The FHWA should [NOT]{.underline} require that bridge inspections be
performed by either a civil or structural engineer who is a licensed
professional engineer. To do so would create prohibitively increased
costs which would be disproportionately high for local surface
transportation agencies. There are a multitude of registered
professional engineers in the surface transportation arena who are
graduates of neither a civil engineering nor a structural engineering
curriculum yet are highly qualified to inspect and report on bridges.

The NBIS regulation should [NOT]{.underline} specify the discipline of
the registered Professional Engineer responsible for bridge inspections
for the reasons enumerated in the preceding paragraph.

There should be no engineer in training component. An engineer in
training who ultimately gains registration as a Professional Engineer
must then determine whether he/she is qualified to act in certain
capacities, as stated above. An engineer in training who does not
subsequently gain registration as a Professional Engineer must comply
with the existing NBIS regulations regarding experience and training.
There has not been a sufficient demonstrated need for such change.

Those performing underwater inspections should [NOT]{.underline} be
required to be qualified licensed professional engineers. This would
create unnecessary additional work and associated costs for all levels
of government involved in surface transportation where there has not
been a sufficient demonstrated need for such change.

**[INSPECTION REPORT]{.underline}**

A regulation which would prohibit the individual in charge of inspection
and reporting from submitting the inspection reports in accordance with
that individual\'s best judgement would not be in the best interest of
the public. It would create situations wherein the subordinate held
authority over the supervisor which would create many more problems than
it would solve.