The City of Cedar Rapids appealed an order by the Iowa Department of Transportation that Cedar Rapids remove automated speed cameras from a state-controlled highway. In this letter, Iowa DOT Director Paul Trombino denies the appeal and cites the grounds for the agency's authority and reasoning.
Original Title
Iowa DOT Director Paul Trombino Denial of Cedar Rapids ATE decision appeal
The City of Cedar Rapids appealed an order by the Iowa Department of Transportation that Cedar Rapids remove automated speed cameras from a state-controlled highway. In this letter, Iowa DOT Director Paul Trombino denies the appeal and cites the grounds for the agency's authority and reasoning.
The City of Cedar Rapids appealed an order by the Iowa Department of Transportation that Cedar Rapids remove automated speed cameras from a state-controlled highway. In this letter, Iowa DOT Director Paul Trombino denies the appeal and cites the grounds for the agency's authority and reasoning.
@IOWADOT
SMARTER | SIMPLER I CUSTOMER DRIVEN iowa. goy
Directors Office
800 Lincoln Way | Ames, IA 50010
Phone: 515-290-1111 | Fax: 515.289-1120,
May 11, 2015
Elizabeth D, Jacobi
City Hall
101 First Sect SE.
(Cedar Rapids, 1A 52401
Fe: Appeal of Automated Traffic Enforcement (ATE) Evaluation
Dear Ms. Jacobi
(On April 16, 2015, the Department of Transportation (DOT) received your appeal of the lowa DOT evaluation
of your ATE annual report. Specfically, you are appealing al ofthe Resulting Actions from the DOT
Evaluation which include disabing the speed detection from the camera atthe 1* Avenue and 10” Street
Intersection, move the northbound cameras on I-380 near Diagonal Drive, removeldisable the northbound
‘cameras on 1-380 at J Avenue, mave the southbound cameras on I-380 near J Avenue and remove/disable
‘the southbound cameras on 1-380 near 1* Avenue.
Your appeal also raises issues rating to DOT's legal authority to implement its ATE rule; the City's home
rule authority; and the procedure DOT followed conceming its ATE rules. Lot me first address these issues.
OTIS LEGALLY AUTHORIZED TO REGULATE THE USE AND PLACEMENT OF ATE UNITS
‘THROUGH ADMINISTRATIVE RULES
Jowa DOT has legal authority to regulate the use and placement of Automated Traffic Enforcement (*ATE")
units on municipal extensions of he primary highway system and to implement such administrative rules, by
Virtuo ofthe following toga authositoe:
lowa Code section 307.2 creates the state department of transportation and provides that it “shall be
responsible for the planning, development, regulation and Improvement of transportation in the state as,
provided by law." (Emphasis added). The director ofthe DOT is expressly authorized to
‘Adopt rules in accordance with chapter 17A as the director deems necessary for the
‘administration of the department and the exercise of the director's and department's powers,
‘and duties.
lowa Code §307.12(1}(). In tum, the lowa Transportation Commission is directed to approve the DOT
‘administrative rules. lowa Code §307.10(15)awa DOT is vested with jurisdiction and control over the primary highways. lowa Code §308.4(1). Iowa
Code section 306.4(4)(2) establishes concurrent jurisdiction between the DOT and the Cty with respect to
“the municipal extensions of primary roads in all muricipalies” and further allows them to consult with each
cther as to the “kind and type of construction, reconstruction, repair and maintenance’ and enter into
‘agreements concerning such. h. Thus, the concurrent jurisdiction exception for municipal extensions of
primary highways is limited to matters involving the "kind and type" of construction and maintenance under
section 306.4(4). Further, the DOT is just required to “consult with the city and the partis are to agree on a
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2022 LiseTo gota better understanding of the crash history for this section of -380 through the downtown area, the
lowa DOT summarized all crashes over 11 years. Here is that information:
‘Since the cameras were activated between June and December 2010, years 2010 and 2011 wore not used in
the evaluation. The above crash data is summarized in the table below.
‘Average Annual Number of Crashes
Tou! Severty of Crash
Crashes Fatal-Major Minor PossUnk POO
Before (2004-2009) $2.17 Wot wl
‘After (2012-2014) 82.83 ooo 10 30 «67 (17
Based on the above crash information:
+ Total and Major Injury crashes stayed the same
- Fatal, Minor, and Possibia‘Unkrawm Injury crashes went dawn
- Property Damage Only crashes went up
In the past few years the lowa DOT has installed many safety countermeasures to this section of :360; many
‘of them as a result of the :380 Safety Auait (inal report March 2008). Some ofthese include instaling cable
‘median barter, placing a high-ricion surface treatment on the west curve, replacelupgrade andor instal
‘new warning signs including curva warning signs, upgrade pavement markings, install delineation on bariors
and bridge ras, and replace burred-out roadway lighting. Because ofthese many safety countermeasures it
|s not possible to datermine the safaty benefit of any one safety countermeasure,
‘Based on the new crash informaton, total crashes essentially stayed the same after the cameras were.
installed. Severity of those crashes decreased some. Many safety countermeasures have been added to -
380 in adition to the ATE cameras therefore it snot possible to determine the impact of any one safety
Countermeasure.
lemoval of “Outbound” Cameras on |
The appeal states thatthe outbound cameras should stay o help keep vehicle speeds lower through the S
‘curve and to allow future averaging of speeds betwoen the cameras. Itis common practice in highway safety
to provide a warning to motorists n advance of an “area of concern”. Such a warning could be a curve
‘warning sign in advance of a cure, work zone signs in advance of a lane closure, or a police vehicle on the
shoulder in advance of a crash aeana Thea ara dona ta get the divers attantion, expacting hina ta slow