Comments on FHWA-2020-0001-0179 (MUTCD)

May 23, 2021

I have no idea if my comments are any good or actually help, but I figured I would try.  I hope, a little, to get a toe-hold in their allegedly metrics-driven brains.


I read all the comments from Toole Design (FHWA-2020-0001-0853, tracking number kn4-yvok-yobh), and agree with them entirely.

A few that I thought were especially on point included:

Placement of crossing signals; these must be accessible from a wheelchair even after typical snow plowing. See attached picture for a bad example (this is a button-requested-signaled-crosswalk across Fresh Pond Parkway in Cambridge, MA). For that particular button, it is also quite close to a road full of sometimes-fast traffic, which can be nervous-making to drivers if a cyclist approaches quickly, and nervous-making to parents with children who wish to cross.

IMG 20190121 182309

Counterflow bicycle lanes; I agree entirely, these should not be unnecessarily restricted. There are some that I use every day on low-traffic roads that are not parking protected, and they are completely fine. If it were up to me, every single road that was “one-way” for the purpose of thwarting cut-through automobile traffic would be two-way for bicycles because of their reduced noise, pollution, and danger to other road users.

I agree with their remarks about way-finding signs. Times are appropriate; in particular, fast riders not only know that they are fast riders, they know how much faster than usual they are, and can deal with estimates for the “average” or “median” bicycling time. (I default to 15% faster than the Google Maps bicycle estimates; this is a thing I know. I can shave off another 15% if I try very hard.)

In urban areas (my commute crosses Cambridge, MA, errands often take me into Somerville) the 85th percentile rule is completely inappropriate. The most basic flaw is that it assumes that which does not exist, “free flowing traffic”. Actual rush hour traffic speeds are roughly the same as the median bicycle speed, or slower.

Furthermore, in the previous year (2020), we conducted a natural experiment on all types of roads to see what would happen to crash rates when we remove cars from the road, allowing traffic to flow more freely at the speeds more often chosen by drivers. The outcome was not favorable; in Massachusetts, the number of fatalities did not fall in proportion to the reduction in traffic (see https://www.bostonglobe.com/2021/02/08/metro/driving-decreased-mass-last-year-not-traffic-deaths/ ). This strongly suggests that prioritizing driver speed will reduce safety, and that the “free flowing” part of the 85th percentile rule is especially suspect.

Regarding urban areas again, whenever there is any consideration for “traffic flow”, it must include all road users (pedestrians, cyclists, drivers, scooters, skateboarders — I see all of these in Cambridge) and mass transit users must be weighted individually; i.e., it is not “one bus” but rather “50 passengers”. This is a bare minimum; there are issues of equity and access that I am not really qualified to comment on but I know they exist. There are roads in Cambridge where the bus traffic at rush hour, counting people, exceeds the car traffic (Mt. Auburn Street). This was used to justify a restricted lane for buses, which improved bus speeds and (I heard, and it would be expected for improved bus service) led to an even larger number of people using the bus. There are intersections (Inman Square) where the summer rush hour bicycle traffic is 30+% of the total (this was estimated by counting cars and counting bicycles; for a 45-second green, that’s about 22 cars, and 11 bikes means 33%; this is relatively common at summer rush, and I’ve seen as many as 20 — and it’s not that welcoming an intersection.) Winter traffic is lower, but this is a case where lack of safety (inadequate separation from traffic; lanes narrowed by snow piles) causes a mode shift; walking or waiting at a bus stop are both actually colder than riding a bicycle (source; my daily bicycle commute, and getting uncomfortably chilled walking to lunch when I forget to bring a jacket for walking. I have been doing this for years, and have had the experience multiple times.)

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