Missouri Bicycle & Pedestrian Federation comments to FHWA regarding proposed changes to national road design guidelines

Today the Missouri Bicycle and Pedestrian Federation joined thousands of organizations and individuals across Missouri and the U.S. in submitting detailed comments about problems with proposed changes to the influential Manual on Traffic Control Devices (MUTCD).

The MUTCD is the national guidance that determines how every road, street, and highway in the U.S. is designed. It is updated about once a decade--and the recently proposed update is very problematic for the safety of people who walk and bicycle.

The MUTCD is the national guidance for all visible parts of the nation's road network--signs, stripes, lanes, crosswalks, traffic signals, and more.   The MUTCD is updated about once a decade.

The recently released draft for the 2021 MUTCD update is very problematic from the perspective of pedestrian and bicycle transportation. Public comments on the proposed updates are due Friday, May 14th, 2021 and can be submitted using the official U.S. government response page here.

However, the simplest and easiest way to submit a public comment is to use the Bike League's automated comment submission form:

League of American Bicyclists automated MUTCD comment submission form

In writing your comment, your are welcome to refer to, quote, or borrow sections of MoBikeFed's letter below. Find more background and information about this issue, including analysis of the issues and recommended comments, in MoBikeFed's article on the MUTCD revision here.

Letter from the Missouri Bicycle & Pedestrian Federation to the Federal Highway Administration regarding proposed updates to the Manual of Uniform Traffic Control Devices

May 13^th, 2021

RE: Proposed changes to the MUTCD must prioritize safety, needs of vulnerable road users

The Missouri Bicycle & Pedestrian Federation is a statewide organization working on behalf of the millions of Missourians who walk and bicycle regularly, with over 5000 direct members and 50,000 members of affiliated organizations across Missouri. We are currently in our 25th year advocating for advancement of bicycle and pedestrian access, safety and education.

The Missouri Bicycle & Pedestrian Federation and our members strongly support the comments submitted by the League of American Bicyclists, AmericaWalks, the National Association of City Transportation Officials (NACTO), and other organizations that ask that this update of the MUTCD provide proactive safety guidance so that the United States can make progress on equity, sustainability, and traffic safety goals. As written, the proposed MUTCD updates choose to prioritize speed and vehicle flow over safety in numerous ways.

The MUTCD should prioritize safety, emphasize road design that reduces or eliminates serious injury and death, and forefront the needs of vulnerable road users, such as those who walk and bicycle, people with disabilities, children and seniors, and people who use public transportation.

 

1. Allow Better Bike Networks by removing restrictions on bicycle traffic control devices.In Missouri, we have seen far too many examples of situations where local decision-makers deny needed bicycle facilities that would improve access and safety because the facility does not meet some detail of MUTCD requirements.
    
2. Orient Streets to People by allowing paint markings that prioritize people walking, biking, and taking transit. Here in Missouri we have seen city public works departments remove beautiful and highly visible pedestrian crosswalk markings strongly supported, installed, and maintained by neighborhood groups because they did not meet MUTCD requirements.  The replacements—which met the letter of MUTCD standards—were ugly, less functional, less visible, and less safe.
    
3. Create a Safe System through proactive safety rather than a reactive warrant system. Many times here in Missouri we have seen crosswalks, pedestrian facilities, and other intersection improvements denied because the intersection did not meet some warrant for including pedestrian access. It is vital to remember that lack of safe facilities greatly suppresses the amount of bicycling and walking in an area. The fact that an area does not currently meet warrants becomes an excuse to deny much needed safe infrastructure for walking and bicycling—and lack of safe places to walk or bicycle is the very reason the amount of walking and bicycling is low in that area.
   
   Standards like the MUTCD should lead and guide communities towards creating and maintaining complete, connected, comfortable, and safe pedestrian and bicycle networks that connect all the places people need and want to go. MUTCD guidelines should never discourage creation of complete, connected, comfortable, and safe bike/ped networks.
   
   
4. In general, we strongly support AmericaWalks request to ensure “every urban and suburban signalized intersection has accessible pedestrian infrastructure,including curb ramps, audible and tactile signals, pedestrian signal heads that display ‘Walk’ and ‘Don’t Walk’ messages, and painted crosswalks.” Even in the year 2021, far too many intersections—including newly installed instersections—in Missouri lack these basic facilities.
    
5. Eliminate the antiquated 85% rule for setting speed limits. We know that slower traffic speeds are one of the most important tools for improving safety, reducing the number of fatal and serious crashes and improving access and safety for vulnerable road users like people who walk and bicycle.  Here in Missouri we have seen sensible and much-needed requests for lower speed limits denied numerous times on the basis of the 85% rule.  The 85% rule is antiquated and not supported by current research.  As AmericaWalks says, the MUTCD should “Set speed limits based on safety, not based on how fast cars are driving on the road.” The MUTCD should allow and encourage road designers to alter road design in such a way as to encourage drivers to adhere to desired operating speeds—the systems-based approach to safety—rather than simply allowing random factors and driver preference to take the lead in this important area.
    
6. Generally, safety for all road users, a systems approach to safety, and the needs of vulnerable road users must be prioritized above traffic flow and speed.
   
   
7. Autonomous Vehicles are a particular problem. Self-driving cars have both great promise and significant peril—particularly for vulnerable road users.  Any guidance must be based on an inclusive and transparent process that fully involves all stakeholders, including representatives of groups working to improve safety and access for vulnerable road users. Autonomous Vehicle Industry voices must not be allowed to dominate the rule-making process.
    
8. Give local residents a voice in what kind of infrastructure is needed and give engineers flexibility to design urban streets that are safe enough for children, seniors, people with disabilities, and other vulnerable road users, to navigate. Our experience here in Missouri is that the urban core of very large cities, outer areas of large cities, inner-ring suburbs, outer-ring suburbs, large rural communities, small rural communities, heavily populated counties, lightly populated counties, and many other specific places and jurisdictions have very, very different needs for traffic control devices.  Facilities like contra-flow bicycle lanes, bi-directional bicycle lanes, green bicycle lanes through intersections, and other signs and markings now commonly used in larger cities, work very well in those highly urban environments.  They may or may not work well in a more suburban or exurban environment, or a small rural community.
   
   The purpose of the MUTCD is to promote standardization of road markings and signs across the nation.  But it is evident that not every sign, marking, or type of infrastructure works equally well in every place.
   
   For far too long, road markings and design appropriate for rural highways has been forced into use in highly populated urban areas, in suburbs, and in the populated areas of rural towns—places where that type of road design is simply not appropriate or safe.
   
   It is not appropriate to force rural road design into areas where it is unsafe and inappropriate.  By the same token, it is not appropriate to force rural communities and counties to use design elements that are proven effective in major urban areas but are unneeded or unworkable in a rural context.
   
   The MUTCD must find guidance, procedures, and a process to foster the kind of location-appropriate design that creates a safe and functional transportation network in all locations it serves.

We appreciate the progress the proposed draft of the MUTCD has made in many areas, the work and contributions of staff, contributors, and committee members from across the U.S., and the openness of FHWA to allowing and carefully considering broad public input on this important update to the MUTCD.

We hope that the recommendations above can be incorporated into the MUTCD before it is released, so that it can become an even more effective document for promoting safety and access for all Americans, no matter their transportation choice.

Submit comments for yourself or your organization using the official U.S. government response page here. Or use the League of American Bicyclists automated MUTCD comment submission form. Read more about the proposed MUTCD changes, and the problems with them, here.

Improving safety for all road users is one of the four primary goals in MoBikeFed's Vision for Bicycling and Walking in Missouri. Working together with local, state, and national organizations with similar aims to have a positive impact on federal regulations and design guidelines that affect the design and safety of every road and street in America is one way we can help reach that goal.

Your ongoing membership and generous financial support help turn our Vision into reality!