MUTCD Notice of Proposed Rulemaking (2020) now available

[kphoger]

Correct.  I'm a doofus.

[NoGoodNamesAvailable]

I don't know if this has been discussed, but the requirement for 6 inch wide pavement markings on 45+ mph roads seems fairly major.

[J N Winkler]

The accel/decel lane between the two loop ramps is only 471 feet long.

Looking at this in Google Street View, now I want to write a story about a man named Oliver Edgemoor.

"Oliver Edgemoor" is more plausible than "Oliver Casa Loma."  (I've been beavering through old plats on the Sedgwick County GIS website and have learned that Edgemoor is just one of many streets in Wichita that had different names when first platted.)

[JoePCool14]

I don't know if this has been discussed, but the requirement for 6 inch wide pavement markings on 45+ mph roads seems fairly major.

Isn't that already standard in most places? What's an example of markings that wouldn't be compliant?

[Big John]

^^ Wisconsin uses 4", and when I worked in Georgia, it was 5".

[Scott5114]

No idea what OK uses, but it ain't 6".

[stevashe]

I don't know if this has been discussed, but the requirement for 6 inch wide pavement markings on 45+ mph roads seems fairly major.

Isn't that already standard in most places? What's an example of markings that wouldn't be compliant?

WSDOT and ODOT (Oregon) definitely use 4" for everything. Although WSDOT did just put down 8" plastic lines on Westbound I-90 down Snoqualmie Pass, which is very much appreciated as in previous years the 4" paint lines would wear off in the winter leaving an almost completely unmarked roadway in the spring most years! (The white edge line on the right was still painted though, and got completely obliterated as per usual.)

[ran4sh]

I've seen 4" pavement striping in GA as well as 5".

[hbelkins]

Kentucky is making a transition from 4" to 6" striping on non-freeways.

[Ned Weasel]

Missouri loves its up arrows though. 🤷

The dreaded red up arrows somehow crept across the border: https://goo.gl/maps/Zd9mthCaWRqsuwrL9

Do any other DDIs have these?  And does anyone if this is a KDOT installation or a city (Manhattan) installation?

[Big John]

Missouri loves its up arrows though. 🤷

The dreaded red up arrows somehow crept across the border: https://goo.gl/maps/Zd9mthCaWRqsuwrL9

Do any other DDIs have these?  And does anyone if this is a KDOT installation or a city (Manhattan) installation?

They shouldn't since it is not allowed in the 2009 MUTCD.

[andy3175]

We are into the last few days to comment, with May 14, 2021 as the due date to comment on the MUTCD update. I've seen quite a few comments loaded onto the MUTCD update webpage related to bicycling, walking, and urban landscapes.

https://www.regulations.gov/document/FHWA-2020-0001-0179

The concerns about bicycling, walking, and urban landscapes is summarized in this CityLab article: https://www.bloomberg.com/news/articles/2021-05-05/it-s-time-to-rewrite-the-road-builders-rule-book

The article notes the following areas of concerns: bicycle lanes and their treatment, speed limit setting, walk signals, crosswalk placement, treatment of non-standard crosswalks (such as rainbow crosswalks), and bus lane treatment and design.

I am thinking of making much more pedantic comments about signage for off-interstate business routes and county routes, since I have seen variation for how these are signed state-by-state, and I think there could be more consistency. I am thinking that if a business route is signed off the freeway, the guide signs should consistently list the business route shield among the advance signs. In my experience, states such as California and Nevada offer one or two roadside signs indicating an exit connects to a business route, while states such as Wyoming and Utah sign the business route on most if not all advance signs.

This type of requirement could hasten the demise of business routes in densely populated, urban areas so as to reduce the message loading on any given sign, but in my experience, most drivers in these conditions do not use the signed business route as a navigational tool (I am thinking of Business Loop 8 along El Cajon Boulevard in San Diego - there are still signs for this route, but few people are aware of its existence ... Historic U.S. 80 is more commonly signed on El Cajon Boulevard these days).

All of the above could be said for county routes, as county route markers on guide signs is nearly nonexistent in California yet is common practice in some other states such as New Jersey. The key thing about county route markers is whether the county route is a helpful navigational tool, and while it is in many cases, it is not always the case (such as Wyoming where many county roads have route numbers, but they are usually known by their names for navigation purposes). So I am not sure if I want to comment on this or not. Maybe it could be a recommendation to show the county route marker on most advance signs if it is known that drivers use the county route marker for navigational purposes.

I think part of the reason California's county routes are not necessarily used for navigation is because they are not shown on the guide signs and are limited in most applications to one or two roadside sign installations.

[JoePCool14]

County routes could definitely be signed better, but they aren't always really necessary. For example, in Illinois, county routes are essentially ignored. I know Lake County does a decent job signing them, but I don't know of anyone who uses them to get around. Everyone uses the street names, not the numbers.

Maybe if county routes were always numbers (ex. 501, 470, 820) instead of things like A51 and B67, more people would use them for navigational purposes.

[Scott5114]

Finally got around to making my comment:

In Section 2A.08, the clause "...when a mixed-case legend is used, the nominal loop height of the lower-case letters shall be 3/4 of the height of the initial upper-case letter." should be clarified. Because lower-case letters are already 3/4 the height of the upper-case letters in font files designed according to the "Standard Highway Signs"  publication, some signage engineers take this section of the MUTCD as an instruction to further reduce the height of the lower-case letters, leading to mismatched font sizes between upper- and lower-case letters, negatively impacting legibility.

A possible clarification may be simply to state "...when a mixed-case legend is used, upper- and lower-case letters shall be proportionally sized according to the Standard Alphabet letter forms shown in the "Standard Highway Signs"  publication."

An example showing a misinterpretation of this clause is attached.

[Scott5114]

A second comment, cause FHWA can't stop me:

FHWA should retain Section 2E.41 and the concept of Freeway and Expressway diagrammatic guide signs for option lanes. Diagrammatic guide signs can  supplement Arrow-Per-Lane sign sequences by showing a driver an at-a-glance "plan view" of an interchange, especially when there are multiple ramps on the left and right side of the roadway. The diagrammatic can then be reinforced with Arrow-Per-Lane signage further downstream. Retaining diagrammatic guide signs allows a signage engineer more flexibility in designing signage solutions for complex interchanges.

Section 2E.18 should allow directional arrows on all Exit Direction signs to be located on the side of the sign consistent with the direction of the exiting movement, including post-mounted Exit Direction signs. Doing so allows for more flexibility in sign layout and can reduce material costs on post-mounted Exit Direction signs.

[Roadsguy]

Have people generally been leaving more than one comment for completely separate points, or just putting it all in one big comment?

[J N Winkler]

In past rulemakings for the 2003 and 2009 editions of the MUTCD, I generally wrote FHWA just one letter (printed to PDF and uploaded to the docket site) in response to each notice.  I don't think it actually matters whether you write a letter, send an email, or post a Web form, or do any or all of these multiple times.  They're all comments in writing.

In the Federal Register notice, the changes FHWA proposes to make are numbered.  When the final rule notice comes out, synopses of comments (classified according to whether they come from private citizens, practitioners, state DOTs, and engineering firms) and FHWA's responses to them will be keyed to these numbers.  My experience has been that while a commenter is free to address any aspect of the MUTCD, comments that are specifically addressed to the numbered changes elicit the most visible responses from FHWA, since they are referred to directly in the comment synopsis (albeit in anonymized form--e.g., "Several private citizen commenters noted . . .," or "A state DOT suggested . . .") and in FHWA's statement of its reasons for agreeing or disagreeing with the comments received on a particular change.

One would hope that FHWA accepts comments that are broader in scope as feedback on the MUTCD or its programs more generally and modifies its policies and approach accordingly, but any response of this type is bound to be subtle enough that it can be discerned only by watching the agency closely over several years.

I believe this approach to digesting and responding to comments is basically Federal Rulemaking 101 and not specific to FHWA.  But it took me one MUTCD revision cycle to see the patterns, and another to verify that they repeat.

This is why I think the eventual Final Rule notice is bound to disappoint assorted segments of the bicycling, livable-cities, and New Urbanist communities who have been vociferous in Facebook groups about their objections to the very idea of having a MUTCD.  I think there is a degree of naïveté in play:  many of these people were not even born when the proposed changes dropped for the 2003 MUTCD, and were still in grade school (a few years shy of receiving unfiltered access to the Internet) when the 2009 edition was on the horizon.  It's possible, even likely, that we will end up with policies that favor elements of their agenda, but this is not a process that is going to begin with jettisoning the MUTCD altogether.

Bottom line:  I encourage you all to go ahead and comment.  Just be aware it will take time to see the results of the process.

[Scott5114]

I mostly broke mine up into two parts because I had a response covering multiple points half-drafted a few months ago and lost it due to a power outage, so I wanted to make sure the most important issue (the 3/4 error) was submitted, lest I get distracted and fail to finish the rest. I am mostly concerned that my comment ended up in the right spot, as it seems that the site allows you to comment on individual notices that are published as part of the MUTCD public comment process (like the one indicating that the public comment period is being extended). I hope FHWA will take it under consideration even if it was posted to the wrong document in error.

J.N. Winkler: Does FHWA tend to respond to comments made by a single private citizen if they are the only one commenting on that particular topic? Also, out of curiosity, have you submitted a public comment yourself?

I am a little confused at what the New Urbanist cadre hopes to even accomplish by opposing the principle of the MUTCD. It is, primarily, a standardization and safety tool, instructing engineers how to allow users to interact with transportation infrastructure and being mostly agnostic as to which approach is taken. It's like attacking a software project's user-interface design team because you don't like the way the program manages memory allocation. One would think that a world with no MUTCD would be more dangerous for bicyclists and pedestrians than one with, because there would be no tool for standardizing bicycle and pedestrian facilities from city to city.

[vdeane]

I am a little confused at what the New Urbanist cadre hopes to even accomplish by opposing the principle of the MUTCD. It is, primarily, a standardization and safety tool, instructing engineers how to allow users to interact with transportation infrastructure and being mostly agnostic as to which approach is taken. It's like attacking a software project's user-interface design team because you don't like the way the program manages memory allocation. One would think that a world with no MUTCD would be more dangerous for bicyclists and pedestrians than one with, because there would be no tool for standardizing bicycle and pedestrian facilities from city to city.

I imagine a lot of them have sent requests for things to be changed to DOTs and other agencies and gotten the response, "no, this treatment is not warranted and/or needed per the MUTCD" and thought "if we just get rid of the MUTCD, they'll have no excuse not to give me what I want".

[NoGoodNamesAvailable]

I am a little confused at what the New Urbanist cadre hopes to even accomplish by opposing the principle of the MUTCD. It is, primarily, a standardization and safety tool, instructing engineers how to allow users to interact with transportation infrastructure and being mostly agnostic as to which approach is taken. It's like attacking a software project's user-interface design team because you don't like the way the program manages memory allocation. One would think that a world with no MUTCD would be more dangerous for bicyclists and pedestrians than one with, because there would be no tool for standardizing bicycle and pedestrian facilities from city to city.

I imagine a lot of them have sent requests for things to be changed to DOTs and other agencies and gotten the response, "no, this treatment is not warranted and/or needed per the MUTCD" and thought "if we just get rid of the MUTCD, they'll have no excuse not to give me what I want".

In fairness, most agencies really don't apply all the standards of the MUTCD equally. Case in point, how many pointless all-way stop signs have been installed to appease residents despite the MUTCD explicitly prohibiting stop signs for speed control? Traffic control decisions are largely political and if the MUTCD stands in the way of what a city wants to do, they will usually just ignore it.

[J N Winkler]

J.N. Winkler: Does FHWA tend to respond to comments made by a single private citizen if they are the only one commenting on that particular topic?

Yes.  On occasion, FHWA also does what the lone private citizen commenter suggests.  (In 2003 there were one or two instances where I was the only person making a particular comment on a suggested change.)

Also, out of curiosity, have you submitted a public comment yourself?

Not yet.  I need to get my act together!  I usually work outward from guide signs (Chapters 2D and 2E) and comment exclusively on Part 2 (upright signs).

I am a little confused at what the New Urbanist cadre hopes to even accomplish by opposing the principle of the MUTCD. It is, primarily, a standardization and safety tool, instructing engineers how to allow users to interact with transportation infrastructure and being mostly agnostic as to which approach is taken. It's like attacking a software project's user-interface design team because you don't like the way the program manages memory allocation. One would think that a world with no MUTCD would be more dangerous for bicyclists and pedestrians than one with, because there would be no tool for standardizing bicycle and pedestrian facilities from city to city.

The thinking appears to be that the MUTCD is inseparable from catering to the motorists' agenda and that participating in FHWA's "piecemeal" public comment process is "working within the system" and, as such, inescapably buying into the primacy of motorized transportation.  What they want is a document where nonmotorized modes are treated as number one.

Don Kostelec has a blog post that goes into how the MUTCD works, some of the institutional norms that come into play in using and revising the MUTCD, and some of the instances in which MUTCD provisions reflect practitioner consensus rather than research results.  It touches on some of the reasons I encourage people to comment when they care what the MUTCD says.  We may not all agree on what it should say, but if we aren't part of the conversation with FHWA, then the MUTCD by default reflects the concerns of others who are.

[ran4sh]

That blog post is full of anti-car BS .

I believe that people can advocate for pedestrians, bicyclists, and public transit without needing to advocate against cars.

[stevashe]

Have people generally been leaving more than one comment for completely separate points, or just putting it all in one big comment?

The FHWA did provide a comment form with a nice table to organize your comments if you have a lot of them, it's probably a good idea to use it if you are submitting a large list of comments.

Link: https://www.regulations.gov/document/FHWA-2020-0001-0002

[Dirt Roads]

Don Kostelec has a blog post that goes into how the MUTCD works, some of the institutional norms that come into play in using and revising the MUTCD, and some of the instances in which MUTCD provisions reflect practitioner consensus rather than research results.  It touches on some of the reasons I encourage people to comment when they care what the MUTCD says.  We may not all agree on what it should say, but if we aren't part of the conversation with FHWA, then the MUTCD by default reflects the concerns of others who are.

There's a number of links to good information here.  It's been quite a while since I was working closely with the MUTCD folks, and all of my railroad contacts have retired and no longer involved.  But I was shocked how many traffic engineers that I know, including two who have switched over to the rail side since I worked with them.

[andy3175]

I went ahead and made the following comment this evening (mostly pedantic, detailed items in keeping with my earlier post):

Thank you for the opportunity to comment. Here are some items for your consideration regarding consistent signage for navigational purposes:

1. Signed county routes (with the pentagon-style shield) are not consistently posted on freeway guide signs. A possible idea would be to recommend posting of the county pentagon route marker on freeway guide signs approaching an interchange with a signed county route. This can be preferred for areas where county route numbers are commonly used for navigation. The states of Florida and New Jersey include county route markers on guide signs, while other states that commonly use county route markers for navigation such as California do not.

2. Off-Interstate Business Routes are not consistently signed from freeway guide signs. In some states, the freeway guide signs approaching a business route interchange are clearly signed with the appropriate business route marker/shield. An example of this is shown on Interstate 80 west at College Drive in Cheyenne, Wyoming: https://www.aaroads.com/west/wyoming080/i-080_wb_exit_364_03.jpg. In other states, freeway guide signs omit the business route shield (route marker) except for one auxiliary sign. An example is shown on Interstate 8 east at Imperial Avenue in El Centro, California: https://www.aaroads.com/california/images008/i-008_eb_exit_114_02.jpg. I request that the MUTCD consider language to make the Off-Interstate Business Route shield appear on all approaching guide signs to help its role in serving navigation. In areas where message loading, limited navigational utility of the business route, or high density of interchanges are concerns, the business route designation could be removed.

3. State named Interstate shields and route markers should be the preferred standard of signage for standalone route markers as well as shields on guide signs. Modern signing practices help to improve legibility of the shield numerals, as evidenced by recent overhead signs installed in Utah: https://www.aaroads.com/ut/015/i-015-n-exit-305-04.jpg. The state name in these shields on the guide sign are not noticeable to most drivers, and for those who do note the state name is embedded in the sign, it gives a chance to again note the state they are in.

I am hopeful these comments, while detailed, can help improve the navigational and safety goals of the MUTCD.

Thank you for the opportunity to comment.