Comments on draft MUTCD

 By the time this posts, RantWoman will have submitted the following comments to the Federal highway Administration about the proposed draft of the Manual on Uniform Traffic Control Devices (MUTCD)

Federal Highway Administration

US Department of Transportation

1200 New Jersey Ave S.E.

Washington, DC 20590

 

May 14, 2021

 

RE: Serious concerns about the MUTCD in its current form

FHWA Docket No. FHWA-2020-0001

RIN: 2125-AF85 Document Number: 2020-26789

 

 

Dear Acting Administrator Pollack and Secretary Buttigieg:

 

The opinions expressed here are mine; I also write, as the co-chair of the WA Council of the Blind Advocacy Committee and drawing on recommendations from the American Council of the Blind Advocacy Committee. I write as an advocate for people with disabilities about a wide range of transportation issues, and as a supporter of America Walks.

 

I live in central Seattle and I make it a point to be aware of transportation concerns for many different people throughout WA.  I use a white cane and do not drive. I mainly get around by public transportation; I often travel with my sister who uses a wheelchair or with my mother who uses a walker and with others who use a variety of mobility aids and mobility skills including guide dogs and other measures. Unfortunately, this also means I collect many scary stories about people having to walk long distances on highway shoulders to reach bus stops, nightmarish street crossings, misaligned and poorly maintained curb ramps and other travel-related causes of severe stress.

 

I have also lived significant parts of my life in CO, MT, and IN so I want there to be safe travel options in both urban and rural contexts. I have a particular personal passion for walking and safe routes to school. I walked to school for all 12 years of public education; that is the sort of minimal exercise habit that lays the groundwork for health through life.

 

I want to raise serious concerns about the current draft Manual on Uniform Traffic Control Devices (MUTCD) under revision by the Federal Highway Administration.   The MUTCD, an obscure technical document, is a major obstacle to the kind of humane, activity-supporting street level changes that are needed in my community and others across the United States. Grassroots advocates like myself have valuable local knowledge that is too often brushed aside by traffic engineers based on the rule-bound 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. Outdated guidance is particularly disturbing in the oncoming age of self-driving cars, artificial intelligence-based Smart Cities efforts. New technologies have potential to make significant contributions to mobility; however there is also potential to get things spectacularly wrong and to greatly increase danger for people using some travel modes without improvement in mobility, reduction in greenhouse gas emissions, and other considerations vital to meet mobility needs in the 21^st Century.

 

Finally, the draft MUTCD endangers the safety of pedestrians who are blind, low

vision and deafblind (hereafter "blind pedestrians" or "the blindness

community") by failing and refusing to require that an accessible pedestrian

signal (APS)   be installed wherever a visual pedestrian signal currently

exists. The proposed 11th edition completely fails to ensure that blind

pedestrians are offered the same opportunity to cross streets safely as are

sighted persons.

 

I join the American Council of the Blind, America Walks and other groups to ask that U.S. DOT perform a comprehensive overhaul of the MUTCD, centering safety, equity,  accessibility, and compliance with the Americans with Disabilities Act and Section 504 of the Rehabilitation act. We need a rule book that is designed to support healthier safer communities, one that:

 

● Encourages planners, traffic engineers and people who travel by foot and other mobility devices, by bicycle, as well as other modes of transportation to collaborate to design safe, sane, continuous travel networks for all travel modes

 

● Does not, for example, allow engineers to demand that an intersection experience a certain mumber of deaths or serious injuries before installing traffic signals but gives people flexibility and strongly encourages people to plan networks for all the kinds of traffic anticipated in the area.

 

● 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.

 

● Even in rural or exurban areas promotes the same standards as above near commercial, governmental, job site, and public service locations such as schools and libraries

 

● Gives local residents a voice in what kind of infrastructure is needed.

 

● Gives engineers flexibility to design travel networks everywhere that are safe enough for children to navigate.

 

What the blindness community needs, and the ADA/Section 504 of the

Rehabilitation Act require the MUTCD to mandate:

 

● If a traffic warrant analysis has determined  that a pedestrian signal is  necessary for a sighted pedestrian to safely cross a street, the same information must be effectively communicated to blind

pedestrians in a way that they can understand and use to promote safety, avoid collisions and reduce or eliminate  the greater risk of pedestrian injury or death the blindness community faces when

crossing a street without an Accessible Pedestrian Signal. 

 

● Elimination of the requirement that an engineering study or traffic warrant

is a prerequisite to justify installation of an APS.

 

● Creation of a transition plan resulting in the replacement of all

inaccessible pedestrian signals with APSs within a reasonable timeframe.

 

● APSs should always be installed wherever and whenever new pedestrian

signalization is  installed in  new construction or when a pedestrian signal

is replaced at the end of its  life cycle.

 

● An APS should always be installed when an existing pedestrian signal is

being altered in a way that could affect its usability such as by adding a

Leading Pedestrian Interval or an Exclusive Pedestrian Phase.  

 

● Because of the unique challenges posed to blind pedestrians, require highest

priority replacement of inaccessible pedestrian signals with APSs whenever a

Leading Pedestrian Interval or an Exclusive Pedestrian Phase is planned for

or in use.

 

● A blind person's request for the installation of an APS should be granted on

a highest priority basis.

 

● Alternative forms of pedestrian signalization such as in-roadway warning

lighting, hybrid pedestrian beacons or a Rectangular Rapid Flashing Beacon

should be used only in conjunction with  an APS..

 

Thank you very much for noting these comments.

Sincerely,

(RantWoman)