Comments on 2021 MUTCD Update

Comments on 2021 MUTCD Update

May 14, 2021

Stephanie Pollack, Acting Administrator
Federal Highway Administration
US Department of Transportation
1200 New Jersey Ave S.E.
Washington, DC 20590

RE: WalkBoston Comments on 2021 MUTCD Update

Dear Acting Administrator Pollack:

With this update of the MUTCD, the Federal Highway Administration has an opportunity to overhaul the current standards and create streets that are safe and equitable for vulnerable users, including people walking and biking. WalkBoston endorses the comments by America Walks, NACTO, Transportation for America, and Transportation for Massachusetts (T4MA) that recommend FHWA reframe and rewrite the MUTCD, creating a path for the creation of comprehensive safety-based guidance. Doing so will allow FHWA and the Biden Administration to make strides towards equity and sustainability, while reducing traffic deaths and serious injuries. 

We wanted to highlight a few issues that are of particular importance to people walking:

Accommodating pedestrians and bicyclists through construction work zones is often an afterthought. It is usually handled with pedestrian and bicycle facility closure signs which result in pedestrians and bicyclists experiencing significant out-of-direction travel, insufficient wayfinding for visually impaired pedestrians, or facilities that don’t meet the preconstruction level of multimodal facility accommodation.  

While the current 2009 MUTCD does outline the need to accomodate all modes throughout construction work zones, it fails to provide the same level of specificity and detail that motor vehicle-focused work zone treatments are afforded.  For example, there are only two pedestrian work zone examples (6H- 28/29) which shows a basic sidewalk closure and requirement for pedestrians to reroute around the work zone by crossing the street. Furthermore there are no bicycle work zone examples to draw from. This general lack of detail often results in the design and contractor community either utilizing the facility closure option or in many cases improvising.  

This ongoing update to the MUTCD provides a significant opportunity to bolster the level of design guidance so that the design and contractor community have better examples to draw from that reinforce that need to accomodate a similar level of facility and minimize out-of-direction travel throughout the work zone location.  The State of Vermont (VTrans) and New York City DOT establish good precedent examples for how to best accommodate pedestrians and bicyclists through construction work zones and should be considered as reference documents to be used in elaborating on best practice design guidance within the updated MUTCD.  

Speed limits are still based on the dangerous and disproven 85th percentile rule, and the draft MUTCD does not go far enough to implement the NTSB’s clear recommendation to no longer use this approach. We are grateful that during your term as Secretary of Transportation in Massachusetts, MassDOT started a review of speed setting policies in order to move away from strict reliance on the 85th percentile and take into account other factors, such as land use and the presence of vulnerable road users. We hope that you can bring that experience to inform the MUTCD on speed setting policies.

Outdated signal warrant requirements focus on the history of pedestrian deaths or current crossing demand, instead of known conflicts or planned land use changes. The MUTCD limits the installation of traffic signals because of the potential that they will slow car travel, and as result the guidelines place pedestrians at risk of being injured or killed – before new signals are recommended. We work with many Massachusetts rural villages that need protected crossings on state-owned highways that don’t satisfy the current crossing demand warrant standards. Kids need to walk to school and reach the library without the fear of speeding trucks barreling through the village center.

Pedestrian signal indications are not required at existing or even new traffic signals. We’ve heard from at least one municipality in Massachusetts that the new MUTCD standards will eliminate their ability to show a countdown running through the white man/walk phase, which has meant that going forward they cannot buy countdown units that display the countdown time remaining with people trying to cross the street. This is a change that not only is inconvenient for people walking, but it presents a potential unnecessary cost burden on communities to have to acquire new equipment going forward. We encourage you to ensure pedestrian signals are included at intersections and can display countdown time throughout the pedestrian phase.

Thank you for the opportunity to comment. 

Stacey Beuttell
Executive Director, WalkBoston

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