MUTCD Notice of Proposed Rulemaking (2020) now available

[mass_citizen]

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.

Lets hope it does disappoint them. However given the media coverage they are getting, the vast number of form letters they've submitted, and the friendliness of the new administration and transportation secretary to this particular lobby, its possible the final rule may be severely delayed, or maybe even a supplemental NPA issued. The acting FHWA administrator is from Massachusetts and I can tell you she is VERY friendly to this group of people and their demands. I wouldn't be surprised at anything at this point.

[mass_citizen]

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.

Common sense would agree with you. The MUTCD has entire sections and chapters devoted to these constituencies. It would seem to be a fair compromise and promote sharing of the road however these people still pound the table to throw out the MUTCD because they truly don't want ANY provisions made for motor vehicles. They literally want to "get people out of their cars" and eliminate all private motor vehicle travel. High gas prices, mileage taxes, higher traffic congestion and therefore increased delays, etc are positive things in their eyes because they believe these things will lead people to abandon their private vehicle in favor of biking and public transit. They are a primarily urban constituency and don't understand life outside their urban bubble. Massachusetts is filled with them, and they carry tremendous weight with politicians due to their incessant lobbying. Just look at all the identical and similarly written form letters submitted as comments.

There is no compromise with them, there is no appeasing them. Nothing will ever be good enough. Just remember that.

[Ned Weasel]

I finally got around to submitting a comment.

I have two comments regarding the new MUTCD:

(1) I would like to see some clarification regarding Section 2E.21, Paragraph 09 of the 2009 Edition: "Overhead Arrow-per-Lane guide signs shall not be used to depict a downstream split of an exit ramp on a sign located on the mainline."  It is often important to show which lane bound for a ramp goes to which destination downstream from said ramp splitting from the mainline.  Is an example such as this allowed: https://goo.gl/maps/5erFsVA8MPWwfmyV7 ?  In the linked example, Renner Boulevard and I-35/Northbound I-435 comprise a downstream split of the exit ramp after it departs the Eastbound KS 10 mainline, and this seems to be very pertinent information to road users needing to know which lane to use.

(2) You have probably received several comments regarding the 85th Percentile Rule for setting speed limits.  Many critics advocate for abandoning that rule, but I have serious concerns with such an idea.  In absence of the 85th Percentile Rule, there would be need for a rational standard to ensure speed limits are related to road geometry and travel conditions, and to ensure cities cannot create speed traps.  If the 85th Percentile rule is removed, I believe it should be replaced with a rational standard for setting speed limits appropriate to road conditions.

Thank you for considering these comments.

[Scott5114]

I think today is the last day for public comments. Get them in while you can!

Lets hope it does disappoint them. However given the media coverage they are getting, the vast number of form letters they've submitted, and the friendliness of the new administration and transportation secretary to this particular lobby, its possible the final rule may be severely delayed, or maybe even a supplemental NPA issued. The acting FHWA administrator is from Massachusetts and I can tell you she is VERY friendly to this group of people and their demands. I wouldn't be surprised at anything at this point.

The problem that lobbying group is going to run into is that, no matter their feelings on the subject, FHWA is always going to need a standard document of some form that says "guide signs are green and red lights mean stop". So the core concept of the MUTCD isn't going to go away, no matter what they try to advocate for.

I think the most likely course of action is that FHWA will lump all comments of that type together and give a polite reply indicating that these comments aren't germane to the process, then spend the rest of their time addressing comments on actual specific sections of the document.

[stevashe]

I think today is the last day for public comments. Get them in while you can!

We have until 11:59 PM EST tomorrow to submit comments, but definitely don't delay! I'm typing mine up right now.

For ease of access for everyone reading this, the comment form is at this link: https://www.regulations.gov/commenton/FHWA-2020-0001-0001

[vdeane]

The problem that lobbying group is going to run into is that, no matter their feelings on the subject, FHWA is always going to need a standard document of some form that says "guide signs are green and red lights mean stop". So the core concept of the MUTCD isn't going to go away, no matter what they try to advocate for.

I wouldn't be surprised if they managed to get concessions on some of their other issues, however, even if they don't end up getting the concept of the MUTCD tossed out (although I think some who want that would be fine with a MUTCD that was started from scratch to favor everything that isn't an automobile).

[kphoger]

We have until 11:59 PM EST tomorrow to submit comments, but definitely don't delay! I'm typing mine up right now.

So, we have until 12:59 AM EDT tonight?

[hotdogPi]

I was at a restaurant on Mother's Day that said they opened at 12:30 AM on Sundays. I'm pretty sure this was a typo and not some near-midnight special.

[stevashe]

We have until 11:59 PM EST tomorrow to submit comments, but definitely don't delay! I'm typing mine up right now.

So, we have until 12:59 AM EDT tonight?

Actually, 11:59 EST is 10:59 EDT

But yes, I did mean 11:59 EDT.

[US 89]

So, we have until 12:59 AM EDT tonight?

Actually, 11:59 EST is 10:59 EDT

11:59 PM EST is 12:59 AM EDT. Have to spring forward an hour when you change in spring.

[Dirt Roads]

We have until 11:59 PM EST tomorrow to submit comments, but definitely don't delay! I'm typing mine up right now.

So, we have until 12:59 AM EDT tonight?

I'm resisting the urge to say "except in Indiana" (which isn't true anymore).

[ran4sh]

I commented regarding their suggested exit numbering rules. While I like the idea that exit numbers can now be adjusted by 1 to avoid letter suffixes, they also are adding a rule that says that letter suffixes should not be skipped and instead should start with A and increase for NB/EB, and for SB/WB should end with A and not have any skipped letters. E.g. if there are 3 letters northbound but 2 southbound, they want the NB exit letters to be A-B-C, with the SB exit letters B-A.

I commented that it's more important for the same cross street to have the same letter, even if a letter has to be skipped in one direction. For example, if "A" is a partial NB exit, then A-B-C on NB should correspond to C-B SB with the A being skipped due to no SB exit.

[PurdueBill]

I commented regarding their suggested exit numbering rules. While I like the idea that exit numbers can now be adjusted by 1 to avoid letter suffixes, they also are adding a rule that says that letter suffixes should not be skipped and instead should start with A and increase for NB/EB, and for SB/WB should end with A and not have any skipped letters. E.g. if there are 3 letters northbound but 2 southbound, they want the NB exit letters to be A-B-C, with the SB exit letters B-A.

I commented that it's more important for the same cross street to have the same letter, even if a letter has to be skipped in one direction. For example, if "A" is a partial NB exit, then A-B-C on NB should correspond to C-B SB with the A being skipped due to no SB exit.

THIS!!  There are so many examples of where the "no skipping" would make the same cross street have different exit numbers in different directions, or the same number serve completely different cross streets.  Exit numbers are then useless!!!

For example right off the top of my head, I-76 in Akron.
Eastbound:
21B:  Lakeshore/Bowery
21C: SR 59 Innterbelt

Westbound
21C: Dart Ave (indirect access to SR 59)
21A: East Ave

By the new guidance, I-76 WB would have to have exits 21B and 21A, for Dart and East Aves in that order.  EB 76 would have exits 21A and B for Lakeshore/Bowery and Innerbelt.  These are basically four different exits.  The existing 21Cs link to each other by Dart being the frontage road for the Innerbelt expressway eventually, but Lakeshore/Bowery  and East serve different areas and should NOT have the same exit number. 

The inverse, the same cross street getting different letter suffixes, is equally probable and shouldn't happen either.  How do they come up with ideas like this?  It's not a problem in the first place.

[J N Winkler]

How do they come up with ideas like this?  It's not a problem in the first place.

I've had this reaction to a few proposed changes in Chapter 2E:

*  Exit direction sign for simple exit (no lane drop) to have arrow to side if overhead, arrow on bottom if mounted to the side (few if any agencies do this currently).

*  Special treatment for lane drops with option lane that have long narrow gores (one of the figures even has a gore sign with an arrow pointing downward and to the side!).

*  Sawn-off APLs with off-center legend (none of the installs I've seen in plan sheets has this).

My comment draft currently has close to 1200 words.  I'm looking to add a couple of comments about the 3/4 error and Clearview, and then I think it will be ready to upload.

[vdeane]

The inverse, the same cross street getting different letter suffixes, is equally probable and shouldn't happen either.  How do they come up with ideas like this?  It's not a problem in the first place.

I wouldn't be surprised if they were trying to find a way to reduce alphabet soup complaints from the states that have yet to convert.

[kphoger]

I'm just assuming there's actual, real-world confusion arising from exit numbers going straight from C to A or whatever.

[PurdueBill]

How do they come up with ideas like this?  It's not a problem in the first place.

*  Exit direction sign for simple exit (no lane drop) to have arrow to side if overhead, arrow on bottom if mounted to the side (few if any agencies do this currently).

Ohio has replaced a bunch of ground-mounted exit sign panels over the last few years that were not that old, not really in need of replacement, but got replaced anyway, to put the arrows on the side instead of the bottom where they had been.  And now FHWA wants it back the way it was???

Was a button-copy sign until about 2006; had plenty of life left (especially considering it's Ohio); got replaced with everything else in the corridor and redesigned...
Replaced in 2017 by this with the arrow on the side; would need to revert to old design!!

The changing standards and guidance are enough to drive one bonkers.

I'm just assuming there's actual, real-world confusion arising from exit numbers going straight from C to A or whatever.

I'm assuming the same street having different exit numbers in different directions or Exit 21A going to completely different places is more confusing than that.  Engineering judgement has to get some allowance here to do what makes sense.

[kphoger]

I'm assuming the same street having different exit numbers in different directions or Exit 21A going to completely different places is more confusing than that.  Engineering judgement has to get some allowance here to do what makes sense.

Yes, I totally get that.  I mean, plenty of businesses' directions say "to Exit 42A" or whatever.

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

[PurdueBill]

I'm assuming the same street having different exit numbers in different directions or Exit 21A going to completely different places is more confusing than that.  Engineering judgement has to get some allowance here to do what makes sense.

Yes, I totally get that.  I mean, plenty of businesses' directions say "to Exit 42A" or whatever.

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

We're going back to sequential world.  Assuming that A is always two exits after C is like assuming that Exit 3 is two exits after Exit 1.  What do the signs say about the distances?  Exit 42A is how far ahead?  Be ready for it!
If they want sequential, then go back to sequential.  If not, then don't.  They need to not mix. 
It's not just for businesses advertising; entire neighborhoods, hospitals people are getting to, etc..  There is no reason to mandate or even suggest that Exit 21A in one direction should go to a completely different street that serves a completely different part of town and doesn't easily connect just to not skip a letter.  It would make more sense in that case to start fudging numbers, which I would bet agencies would start doing if they can in cases where there are numbers available and it makes sense to do it.  Would that mean it backfires on FHWA?  Yep.  Would it serve them right?  Yep.

[US 89]

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

So as a driver who sees a regular exit 42, does that mean exit 39 is three exits later?

[kphoger]

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

So as a driver who sees a regular exit 42, does that mean exit 39 is three exits later?

Hey, now.  I've grown up with mile-based exit numbers my whole life, and I've understood for just as long that letter suffixes don't work the same as the numerical part.  It doesn't take too many instances of 42A-42B-42C, 110A-110B-110C, 5A-5B-5C to figure out how it works.  That's why I'm saying that skipping a letter can lead to confusion.

[Scott5114]

How do they come up with ideas like this?  It's not a problem in the first place.

I've had this reaction to a few proposed changes in Chapter 2E:

*  Exit direction sign for simple exit (no lane drop) to have arrow to side if overhead, arrow on bottom if mounted to the side (few if any agencies do this currently).

I specifically commented against this standard to request that arrow to side be allowed on post-mounted installs. Putting the arrow on bottom on a sign like this one would waste a whole lot of panel space without much benefit at all other than standardization in sign layout. Personally, if I were to choose one or the other to standardize on I'd standardize on arrow-to-side for that reason alone.

*  Sawn-off APLs with off-center legend (none of the installs I've seen in plan sheets has this).

The off-center legend in the specimen diagram does center the text between the arrowheads applying to it. While off-center text appears jarring to anyone who isn't inculcated to it by Oklahoma signage, it does appear to be a deliberate decision to do it in order to emphasize that the legend block does not apply to the up arrow.

I was a little curious as to the effectiveness of sawn-off APL, so I showed the specimen to a non-roadgeek friend of mine and asked her opinion of what it meant, and she nailed it, so they perform well on that regard, at least.

My comment draft currently has close to 1200 words.  I'm looking to add a couple of comments about the 3/4 error and Clearview, and then I think it will be ready to upload.

Be sure to post a copy here when you're finished.

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

So as a driver who sees a regular exit 42, does that mean exit 39 is three exits later?

Hey, now.  I've grown up with mile-based exit numbers my whole life, and I've understood for just as long that letter suffixes don't work the same as the numerical part.  It doesn't take too many instances of 42A-42B-42C, 110A-110B-110C, 5A-5B-5C to figure out how it works.  That's why I'm saying that skipping a letter can lead to confusion.

I don't know that most non-roadgeeks would even notice a missing letter. I think for most people it works the same as when you are hunting for an address–use the surrounding numbers to indicate when you're getting close and then when the exit is imminent search for the specific number you want and discard as irrelevant any information about exits that are not that number. If they didn't see a 5B between 5C and 5A I imagine most people would assume they just overlooked it if it weren't their exit number.

[kphoger]

I don't know that most non-roadgeeks would even notice a missing letter. I think for most people it works the same as when you are hunting for an address–use the surrounding numbers to indicate when you're getting close and then when the exit is imminent search for the specific number you want and discard as irrelevant any information about exits that are not that number. If they didn't see a 5B between 5C and 5A I imagine most people would assume they just overlooked it if it weren't their exit number.

Yeah, well my imagination could beat your imagination up!

[Scott5114]

I don't know that most non-roadgeeks would even notice a missing letter. I think for most people it works the same as when you are hunting for an address–use the surrounding numbers to indicate when you're getting close and then when the exit is imminent search for the specific number you want and discard as irrelevant any information about exits that are not that number. If they didn't see a 5B between 5C and 5A I imagine most people would assume they just overlooked it if it weren't their exit number.

Yeah, well my imagination could beat your imagination up!

Wanna reread the Alanland thread and say that to me again?

[stevashe]

I'm assuming the same street having different exit numbers in different directions or Exit 21A going to completely different places is more confusing than that.  Engineering judgement has to get some allowance here to do what makes sense.

Yes, I totally get that.  I mean, plenty of businesses' directions say "to Exit 42A" or whatever.

But I also imagine that a driver, upon seeing Exit 42C, assumes that Exit 42A will be two exits later.

We're going back to sequential world.  Assuming that A is always two exits after C is like assuming that Exit 3 is two exits after Exit 1.  What do the signs say about the distances?  Exit 42A is how far ahead?  Be ready for it!
If they want sequential, then go back to sequential.  If not, then don't.  They need to not mix. 
It's not just for businesses advertising; entire neighborhoods, hospitals people are getting to, etc..  There is no reason to mandate or even suggest that Exit 21A in one direction should go to a completely different street that serves a completely different part of town and doesn't easily connect just to not skip a letter.  It would make more sense in that case to start fudging numbers, which I would bet agencies would start doing if they can in cases where there are numbers available and it makes sense to do it.  Would that mean it backfires on FHWA?  Yep.  Would it serve them right?  Yep.

You *might* want to go back and reread that section, then submit another comment if that's how you feel. The proposed MUTCD actually includes fudging, not just in a Guidance statement, but as a full Standard as well!!!! I was sure to write a lengthy comment arguing against that one (quoted below).

Page 209, Lines 43-35; and Page 210, Lines 18-20 — Disagree with recommending that interchanges within the same mile can have separate numbers to avoid suffix letters. This Standard and Guidance, especially as written, go against providing uniformity in exit numbering as it is up to the agency maintaining the roadway to determine what distance between interchanges constitutes "so closely spaced that it is impracticable to use separate exit numbers."  This could lead to situations where, for example, EXIT 2, EXIT 3, and EXIT 4 are all within one mile of each other, with a subsequent gap of two to three miles between EXIT 4 and EXIT 5. This effectively makes the numbering more like the consecutive exit numbering method, and could be confusing to road users who would expect more uniform spacing of consecutively numbered exits under the reference location sign exit numbering method.