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Our Submitted Comments to the Federal Register on the Manual on Uniform Traffic Control Devices

For being what we were just recently referring to as The Most Important Pedestrian Safety Document You’ve Never Heard Of, an impressive 25,000 plus comments were submitted to the Federal Register on the notorious Manual on Uniform Traffic Control Devices (MUTCD).

As a result of the incredible work of advocates like you, plus the vocal and collective active networking of major transportations and mobility organizations in our sphere, people seem to be waking up to the painful realities of the MUTCD and the incompetent, dangerous ways it dictates every single street design in the U.S.

For your records and reference, below is the official letter we submitted to the Federal Register. Stay tuned for next steps on what changing the MUTCD will look like once this process wraps up.

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: 

We write, to raise serious concerns about the current draft MUTCD under revision by the agency. The MUTCD, as drafted, is a major obstacle to the kind of humane, activity-supporting, street-level changes that we at America Walks exist to support in communities across the United States.  

The grassroots walkability leaders we fund and train have valuable localized knowledge that is too often brushed aside by traffic engineers based on the rule-bound dictates of the MUTCD.

“I bike or walk my kids to school every day, and every day face the challenges that make a walkable world so inaccessible for most people,” said Antonia from Montana, in one of the dozens of official comments submitted by our grassroots supporters.

Even allied practitioners are thwarted in efforts to address urgent local street safety matters as testimonials we collected demonstrate, like Jessica Mathews in Delaware, Ohio, and Don Kostelec in Garden City, Idaho. We urge you to watch these videos, as well as videos from the Disability Mobility Initiative in Washington.

To make matters worse, much of the guidance is outdated, pseudoscientific and based on the premise that speeding cars through intersections is the most important goal. These standards are especially damaging in cities, where over the last decade has been a time of intense interest in active transportation, as officials from the National Association of City Transportation Officials and the City of Fort Lauderdale, Florida, outlined in our April webinar on the topic

We at America Walks and many other active transportation groups are asking that the U.S. DOT perform a comprehensive overhaul of the MUTCD, centering safety, equity and accessibility. Without getting into a lot of technical detail, we need a rule book that is designed to support healthier safer communities, one that: 

  • 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.
  • Set speed limits based on safety, not based on how fast cars are driving on the road.
  • Gives local residents a voice in what kind of infrastructure is needed rather than an arbitrary one-size-fits-all standard.
  • Gives engineers flexibility to design urban streets that are safe enough for children to navigate.
  • Takes into account the wide range of ages and abilities of those that use streets.
  • And most importantly, helps support active, diverse and vibrant neighborhoods and communities. 

We also urge FHWA to change the process for updating the MUTCD to ensure diverse voices are heard. While framed as a technical document, it is based on foundational values, and those values belong to the entire community, not just the technical experts. All future processes to amend or rewrite the MUTCD must include a broad range of community perspectives, as well as voices from related disciplines like public health and urban planning.

We are strongly asking 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. 

Thank you, 

America Walks Executive Director, Mike McGinn and Staff and Board