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Advocacy Action: Help update U.S. road standards for safer streets

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An 800+ page federal document that has cemented unsafe road designs in our communities is being updated.

You can help make our streets safer by weighing in on the process. Trailnet and national partner organizations are calling on U.S. Transportation Secretary Pete Buttigieg to overhaul the document to prioritize safety for people walking and biking.

Our sample comments are below, Friday May 14 is the deadline to add comments. You can submit your comments here.

Background on the MUTCD

This spring the Federal Highway Administration is reviewing an enormous document called the MUTCD (Manual on Traffic Control Devices). This manual provides traffic engineers with regulations and guidance for items like signage, markings, and roadway design for all U.S. roads.

Side by side comparison of two situations: one is a rendering of a street crossing with a colored crossing, painted bike and bus lanes and a stop of pedestrian sign with the text NOT ALLOWED, the other is a seven lane road with two adults' and a child in the median tryin to cross with the text MUTCD compliant
NACTO (National Association of City Transportation Officials)

For the first time in 10 years, the MUTCD is up for review. Now is a great opportunity for the public to weigh in and help fix a document that fails to address everyday street safety. Regulations in the MUTCD consistently undermine the safety for people walking and biking while prioritizing convenience for people driving cars.

This failure is evident in how our current road design standards continue to create an environment that is unsafe for people walking and biking. In St. Louis County and St. Louis City, total deaths (walking, biking, and driving) have been steadily rising since 2010, with over 170 deaths in 2020, the highest in that 10-year period.

NACTO (National Association of City Transportation Officials)

Priority Areas in need of Immediate Fixing: Trailnet agrees with other likeminded organizations like NACTO (National Association of City Transportation Officials), America Walks, and The League of American Bicyclists. Together we agree that in order to prioritize safety for people walking and biking, a complete overhaul and rewrite of the MUTCD is desperately needed.

This rewrite must address key priorities like:

  1. The 85th Percentile Rule: The MUTCD advises traffic professionals to use an outdated metric called the 85th percentile rule. This rule sets speed limits at the speed where most people (85% of drivers) drive normally. Meaning that based on the size and type of road and given normal flows of traffic 85% of people drive below that set speed limit.
    This creates a cycle where each time speed limits are reviewed they are progressively increased. We know from NACTO’s City Limits document that “relying on [this type of] system focused on driver behavior, rather than a defined safety target to set speed limits, significantly limits the ability to reduce traffic deaths.” This “Rule” should no longer exist and should be phased out of the MUTCD.
  2. Pedestrian Signal Requirements: The MUTCD does not require pedestrian-specific crossing signals to be installed at existing or new traffic lights. It instead relies on measures like previous pedestrian deaths and the number of people crossing  to warrant new pedestrian signals.
    Additionally, the MUTCD doesn’t allow other factors such as: expected pedestrian traffic or the number of people who drive to cross busy streets instead of walking to justify adding signals for people walking. Currently, for a signalized pedestrian crossing to be added to a school, the MUTCD requires that there already be 20 children willing to risk their lives at crossing the street in an hour, before a signal can be added to protect them.
  3. Crosswalks Guidelines: The MUTCD severely lack proactive safety regulation covering the installation and use of crosswalks. For a new signalized crosswalk to be installed, a location must have 93 people cross the street per hour or have had 4 or more pedestrians crashes in a 3-year period. The MUTCD also does not allow for colorful crosswalks within the roadway, even though high visibility crosswalks have been proven to enhance pedestrian safety, while also contributing to neighborhood vibrancy. 
  4. General Lack of Standards for Pedestrian Safety: Throughout the MUTCD there are several sections that mention pedestrian safety measures. However, a lot of those measures are not a federal regulation, but mere guidance that is not legally required for traffic professionals to adhere to.
  5. Regulations that Deter Important Bike/Ped/Transit Projects: Within the MUTCD there are several regulations that can potentially deter things like bike lanes and bus rapid transit projects. For example, there are specific design requirements for bike lanes that cross driveways and certain intersections. Bus rapid transit projects often require expansive and expensive traffic studies that delay these types of projects, which prohibits cities from making strides to expand their public transit networks.
NACTO (National Association of City Transportation Officials)

It should be mentioned that a majority of these comments and areas for improvement are shared among organizations like NACTO, America Walks, Trailnet and other similar biking and walking advocacy organizations. The fact that many national organizations have shared similar criticisms to this document shows the weight in how several regulations and standards impact the safety of people walking and biking on our streets. For more information on other MUTCD comments from those other organizations, we suggest these resources:

Trailnet is also realistic in the fact that a complete overhaul and rewrite of this document will take time to create and approve, and we believe that many of the current proposed amendments, are better than continuing with the 2009 version. As such we have crafted some specific suggestions to these amendments that could be incorporated while a full overhaul of this document is undertaken. You can read our specific immediate suggestions here, with the perspective that a full overhaul is still very much needed. 

People’s lives and safety are jeopardized by the current document. While the proposed amendments make things marginally better, FHWA and Transportation Secretary Pete Buttigieg should act with conviction and expediency to  overhaul this document. Every minute wasted subjects our most vulnerable road users to the faulty logic within this document that prioritizes the convenience of people driving over the lives of people walking, biking, and trying to cross the street. 


Below is a comment template that you can copy, paste, and input into the Federal Register’s comment portal. Feel free to customize this letter with some of the specific advocacy pushes that are important to you.

Friday May 14 is the deadline to add comments. You can submit your comments here.

Sample Letter Text

Federal Highway Administration 

US Department of Transportation 

1200 New Jersey Ave S.E. 

Washington, DC 20590

RE: Serious concerns about the MUTCD in its current form

Dear Acting Administrator Pollack and Secretary Buttigieg,

As a supporter of Trailnet, and a person who _________, I am commenting to elevate certain concerns about the Manual of Uniform Traffic Control Devices. Here in St. Louis we have seen an increase in traffic fatalities and crashes over the last 10 years and federal standards and guidelines (like those in the MUTCD) have done little to regulate how roadways should be designed to promote bicycle and pedestrian safety, and in many cases have actively worked against it. These fatality rates are not unique to St. Louis, these trends are being seen across the United States and other like minded advocates like myself welcome an MUTCD that works for all road users, not just those using a motorized vehicle.

Documents like the MUTCD perpetuate out-of-date street design guidance and absurd regulations that prioritize the efficiency of moving traffic over the safety of people walking and biking. I join Trailnet and other transportation advocacy groups like America Walks, NACTO, and the League of American Bicyclists, to ask that the Manual on Uniform Traffic Control Devices be completely rewritten with a focus on enhancing pedestrian and bicyclist safety. Specifically, revisions to the MUTCD need to focus on:

  • Prioritizing safety over speed. This means relying less on the 85th percentile rule and more on safety for all road users. 
  • Standards that put the safety of people walking first on signalization and markings at intersections. This includes requirements for crosswalks and pedestrian signals at all intersections, relaxing regulations on colored crosswalks, and increasing the time pedestrian signals last, among other things.
  • Supporting pedestrian, bicycle, and transit projects that improve mobility for those users,in a way that doesn’t delay project timing, incur unnecessary costs, or deter these projects in general. 

In conjunction with Trailnet and many others, I formally ask that the Federal Highway Administration rewrite the MUTCD in a way that prioritizes safety for people walking and biking, and allows traffic engineers and professionals to effectively plan and design roadways that encourage people to use core transportation options like walking, biking, and the use of public transportation.

Thank you, 

[your name]