December 22, 2000
Millennium Edition MUTCD – Team Leader
Office of Transportation Operations (HOTO)
Federal Highway Administration, Room 3416
400 Seventh Street SW
Washington, DC 20950
Re: Statutory Speed Limit Definition – inclusion in MUTCD illegal act
Addendum - Traffic Signal Warrants
The STATUTORY LIMIT inclusion in new MUTCD caused another visceral reaction when I was reading the signal warrant section. In regards to the inclusion of Statutory Limit definition and use in the traffic signal section of the MUTCD - this application screams insanity from a safety stand point and violates every basic tenet and the objectives of conducting traffic engineering studies. A gross violation of safety protocols.
E. The posted or statutory speed limit or the 85th-percentile speed on the uncontrolled approaches to the location.
Statutory Limits are pure speculation and conjecture and as a rule never represent the actual prevailing intersection traffic approach speeds. Many are set at or near the ZERO percent speed or less - no where near the 85th, prevailing speed or upper end of the pace speed that is the engineering standard.
1 Every design component of the intersection, roadway feature and traffic control device being specified by uninformed politicians.
2 Turn lanes that are too short, warning signs that may be warranted not being installed, improper placements of signs to give adequate warning etc. A violation of every professional standard there is.
3 Every aspect of the resulting intersection design and signal timing increases the probability of catastrophic accidents.
4 How would a motorists discern on the approach to an intersection that the timing of the yellow is truncated here as compared to the same type of intersection on the same roadway 5 miles back where it was set to reflect the prevailing speed.
5 A violation of the PRIME DIRECTIVE of the National MUTCD, that all traffic control be uniform in application.
Section 1A.06 Uniformity of Traffic Control Devices
Uniformity of devices simplifies the task of the road user because it aids in recognition and understanding, thereby reducing perception/reaction time.
Uniformity assists road users, police officers, and traffic courts by giving everyone the same interpretation. Uniformity assists public highway officials through efficiency in manufacture, installation, maintenance, and administration. Uniformity means treating similar situations in a similar way.
The use of uniform traffic control devices does not, in itself, constitute uniformity. A standard device used where it is not appropriate is as objectionable as a nonstandard device; in fact, this might be worse, because such misuse might result in disrespect at those locations where the device is needed and appropriate.
Any Intersection or Traffic Control Device whose basis is a definition that has NO BASIS-IN-FACT or STANDARD TO MET is a clear violation of sound practices and Section 1A.06. This is compounded by your inclusion of the latest ITE guidelines by reference that has somehow incorporated a truncated yellow interval-timing standard that was never adopted by the ITE.
In the press we are being bombarded by the national crisis of intersection accidents while the organization delegated to oversee and take corrective actions has adopted procedures that are contrary to known sound engineering practices.
The NHTSA is in a headlong rush to be at the center of the Red Light Camera industry where localities have turned this absence of accepted engineering practice (MUTCD) into profit centers. After reviewing studies is Australia where wide spread camera use was evaluated (no effect on accident rates) where they had a control group of intersections where signal timing was adjusted (reduced accident rates); and similar findings from studies in England and the Minnesota AAA. It turns out that for less than the cost cameras, up to a 50 percent reduction in accident rates can be obtained by simply applying existing sound engineering practices to guide the traffic traveling at that sites measured uncontrolled prevailing traffic approach speeds.
What do we know, when a traffic engineering study is done and all traffic control decisions are based on a finding of fact for the highway/intersection being regulated (prevailing speeds as found) - the desired reduction in accidents is achieved.
This illustration of how this Statutory Speed Limit inclusion is contrary to safety objectives is self evident, looking forward to hearing from you soon. Please feel free to contact me if I can be of any assistance in expediting this process.
National Motorists Association
Box 141 Zephyr Cove, Nevada 89448
Link to Addendum Dated 01/01/01