May 13, 2021 Stephanie Pollack, Acting Administrator Federal Highway Administration US Department of Transportation 1200 New Jersey Ave S.E. Washington, DC 20590 RE: Request for an expedited reframing of the MUTCD as a proactive safety regulation We, the Costa Mesa Alliance for Better Streets (CMABS), write as supporters of America Walks, NACTO, and many other organizations and even cities that have spoken out against this draft MUTCD that is currently under revision by the FHWA. The MUTCD, a technical document that is obscure to many, is a major obstacle to the kind of humane, activity-supporting street level changes that are needed in our community and others across the United States. We are a local 501(c)3 nonprofit that works to improve the quality of our public spaces. Our city streets were designed post WWII and per the standards and guidelines of the MUTCD, yet are overrun with cars being operated by inattentive and reckless drivers. We advocate for simple solutions to make walking, biking, and taking transit comfortable and convenient for more people. But when regulatory documents like the MUTCD assume driving as the default mobility mode, it thwarts our work for reasonable street modifications that are intended to make our neighborhoods and city better. Grassroots advocates like us have valuable local knowledge that is too often brushed aside by rule-bound traffic engineers based on the dictates of the MUTCD. To make matters worse, much of the guidance is outdated, pseudoscientific, and based on the premise that speeding cars through intersections is the most important goal. To date, the MUTCD has done little to help stem the approximately 40,000 traffic deaths the U.S. sees each year. Arguably, this is due largely to the Manual’s over-emphasis on motor vehicle operations and efficiency on rural highways, and its neglect of other modes and contexts. This is a dramatic and sobering fact that is very much worth stopping to think about. Therefore, we join America Walks, NACTO, and many other organizations and cities to ask that the U.S. DOT perform a comprehensive overhaul of the MUTCD, centering on the comfort, convenience, and safety of all users of our public spaces, and prioritizing those most vulnerable. We need a rule book that is designed to support healthier communities, one that: ● Uses a safe systems approach to determine appropriate urban speed limits rather than “prevailing speeds.” ● Gives local residents a voice in what kinds of street designs are best for the community. ● Gives engineers flexibility to design urban streets that are safe enough for children to navigate. ● Eliminates the newly-proposed barriers to the implementation of bicycle and transit infrastructure. ● Ensures 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. ● Reduces or eliminates the high standards for warranting traffic control devices that are intended to slow down traffic and increase safety. ● Does not accommodate automated vehicles, which can only exacerbate already prohibitive cost burdens for cities and make our public spaces less comfortable and safe for other street users. The issues described above are endemic to the document’s underlying approach and undercut efforts to provide safe, multimodal accessibility in urban settings. The MUTCD needs holistic reframing to support cost-effective, sustainable, and equitable city street design and improve safety and accessibility for the most vulnerable users. We respectfully request that FHWA reframe and rewrite the MUTCD, creating a path for guidance that more closely aligns with the equity, safety, and sustainability goals of American cities, as well as those of the Biden Administration. CMABS stands ready to work with you. Thank you, Board of Directors, Costa Mesa Alliance for Better Streets Costa Mesa, CA
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