Presented to San Diego City Council October 14, 2002

Safety Analysis:
San Diego’s Proposed Red Light Camera Program

By Chad Dornsife, National Motorists Association

Executive Summary:

This analysis examines and comments on the testimony given at the September 17, 2002 Red Light Camera hearing, the proposed solutions as well as the proposed 4 second minimum yellow interval timing. More importantly if safety is your objective, this analysis provides the blueprint for a safety policy that is known to dramatically reduce accident rates. A solution that, in fact, was codified into federal traffic safety standards in 1988, a safety practice that San Diego has yet to embrace.

The testimony largely centered around commonly held “Safety Myths”, typified by a former traffic reporter. Then there was the camera vendor, represented by former highway patrol commissioner whose poster child of success is the city of Washington DC, a city where the Mayor has publicly stated that the camera program is for revenue, not safety. Convicting citizens of camera generated traffic violations at a rate of more than one a year for every man woman and child in the District. Not satisfied there, they jointly announced a new objective of increasing this already incredulous number by a factor of four or more. DC does not do traffic studies and virtually all their limits are 10-15-20 miles per hour and more below the 85th percentile speed. Posted limits that the commissioner knows full well are nothing more than barefaced speed traps, yet he is very proud of his company’s productivity levels (profit) and support of this for-cash enterprise.

Then there was a sad story by the Mayor of a tragic signal accident, a portrayal that included every red flag there is that this could have been prevented if San Diego’s engineers had been following the prescribed safety protocols for signal timing. In engineering terms, this child more than likely died because of an “inadequate for conditions” yellow interval and all red. Simply put, the young boy most likely was watching the signal head and responded to a green light when known entries on red where still occurring. (added 11/25/02) A second tragic fatality there reported at today's meeting makes it an absolute probabiltiy these were engineering defect caused events.

For a fraction of the cost of the camera systems, an AAA sponsored program in Michigan resulted in a greater than 50 percent reduction in intersection accidents. If these practices were to be applied on all streets citywide, significant reductions in injury accidents and roadway congestion would be obtained … and as an added bonus air pollution would be measurably reduced.

Using the AAA example to achieve “True Safety”, the solution is almost too simple. Rule one is to make sure that all traffic control meets the traffic’s needs and provides adequate warning. Rule two is to reduce all flow conflict and friction and remove or mitigate for all hazards where possible. And the final and most important rule, make sure that only verified vetted practices be followed.


Introduction:

During my testimony I spoke of federal safety laws that San Diego is not in compliance with codified safety precepts that do reduce accidents, improve flow and if applied as they were meant to be, improve safety for all.

In San Diego’s case the statutory practices have, at best, have been treated as minimums leaving many unsafe conditions with inadequate solutions. In effect, with no solution at all where serious accidents continue unabated, and with other insanely unsafe conditions being ignored altogether.

And San Diego’s Traffic Committee also facilitates unsafe practices. If the public myth is contrary to the proven solution, then education is needed, not the placation of citizens with devices or practices that are known to make our roads less safe. Which is in fact, the very reason this law became the Nation’s Traffic Control Standard.

This safety law is called Title 23 and its designated National Manual of Uniform Traffic Control Devices (MUTCD). Since the adoption of the 1988 Edition and further refined in the Millennium Edition, the National MUTCD has been decreed as the statutory minimum requirement for “all traffic control devices installed on any street, highway, or bikeway open to public travel … regardless of type or classification of agency having jurisdiction … no exceptions”.

MUTCD: Millennium Edition
“The U.S. Secretary of Transportation, under authority granted by the Highway Safety Act of 1966, decreed that traffic control devices on all streets and highways open to public travel in accordance with 23 U.S.C. 109(d) and 402(a) in each State.”

“The need for uniform standards was recognized long ago. The American Association of State and Highway Officials (AASHO), now known as the American Association of State Highway and Transportation Officials (AASHTO), published a manual for rural highways in 1927 and the National Conference on Street and Highway Safety (NCSHS) published a manual for urban streets in 1930. In the early years, the necessity for unification of the standards applicable to the different classes of road and street systems was obvious. To meet this need, a joint committee of AASHO and NCSHS developed and published the original edition of this Manual of Uniform Traffic Control Devices (MUTCD) in 1935. That committee, now called the National Committee on Uniform Traffic Control Devices (NCUTCD), though changed from time to time in name, organization, and personnel, has been in continuous existence and has contributed to periodic revisions of this Manual. The FHWA has administered the MUTCD since the 1971 edition.”

Since 1944 compliance has been mandated on all federally funded projects during construction. In the 1971 edition it became recommended practice for all roadways and mandatory for the look and shape of all new traffic control devices. This all changed in 1988.

With the 1988 MUTCD edition, a change in the US Code of Federal Regulations, it transformed prior recommended practice into a binding minimum statutory requirement on all roadways open to the public “regardless of type or classification of agency having jurisdiction.” It provided for a two-year period for each State to bring all traffic control devices, engineering practices, and procedures into compliance. It also required them rewrite their state and local statutes with conforming language, and to cause all non complying devices to be upgraded or removed (some changes have longer phase-in periods). These were funded mandates.

This change in the US Code also mandated conformity with MUTCD referenced “nationally recognized” professional engineering standards and practices – therefore, they too in effect became federal law.

There is no requirement to directly reference the law in state statutes. Notwithstanding, compliance is compulsory. For over three decades now, administrators in every state routinely certify compliance to receive Title 23 benefits. Nevertheless, its actual mandates remain virtually unknown to legislators and every other political entity within the state exercising regulatory and policing powers. THE RESULTS: widespread noncompliance with the law, confusion and chaos when the issue is raised!

In regards to signal timing, the first SHALL it was to be based on the findings of an engineering study and the second SHALL was the timing was to be set to “meet the traffics needs” as documented for a particular location. Like a speed survey per se, these studies produce a bell curve of how long it takes traffic to stop after the onset of the yellow interval. The study is to chart the actual stopping patterns of the traffic and the yellow interval timing is to be set to meet the 97-99th percentile of the traffic’s needs. A third SHALL was these “needs” are to be reviewed on a regular basis to make sure any changes in traffic patterns were being met. Since 1988 this was a “SHALL” in the federal regulations, and San Diego has never conducted such a study, ever, nor are they part of the proposed new changes.

With the Millennium edition, the wording was changed to allow signal timing to be based on the posted speed limit. However, a posted speed limit requires an engineering study, it shall be documented, it shall be established in accordance with nationally recognized practice. This signal timing addition was not vetted and was placed there to placate those who claimed they didn’t have the funding to do studies. And safety is being compromised again.

Nonetheless, the starting point of the numeric posted on a speed limit sign shall be the 85th percentile speed of free flowing traffic rounded up to the next 5 mph increment (10 km). More importantly, the speed surveys that are being done to meet California’s speed trap law do not meet the federal requirements. They are inadequate in sample size, often reporting all traffic from impeded flow locations that could have been collected as long as 7 years ago? (Federal limit 5 years or conditions change) Consequently they always report lower than actual off peak and free-flowing section prevailing speeds; which have been documented to vary 5 mph and more, depending on the time of day or day of week. Again resulting in short yellows where cross traffic by design is being given the green when known entries are still occurring, particularly in California where no all red is the default practice. Even if you include San Diego’s one second all red they are still inadequate – read unsafe.

Worse yet and compounding the problem, the Caltrans chart for signal timing is from an unverified thesis put forth largely by camera proponents that claimed you could shorten yellow timing to improve system efficiencies, and compel compliance with the shorter yellows by enforcement.

Wherein fact the cameras have recorded that neither is true and safety has been compromised. And as a result of those that have been adopting these inadequate practices are in. The nation has been experiencing an actual increase in intersection accidents counter to the overall downward trend.

The blame here can be nowhere except with the Federal Highway Administration, the custodians of the Nation’s safety practices, for allowing unsafe and unvetted practices into the National Standard and endemic known unsafe practices, such as San Diego’s to be practiced in the first place. Ironically the worst example of profiteering from poor engineering practices can be found in our Nation’s capital, and they refuse to act even when these clear violations are obvious to all.

Staff AAA safety engineers knew there was a better answer and they convinced their parent company to test their beliefs. Their safety solution, in effect, was nothing more than to consciously apply the prior vetted best safety practices and standards, making sure that all approaches were properly engineered and that the signal timing met the traffic’s needs. Result: the engineers thesis was verified and engineering solutions do work … and the city where the study was conducted was rewarded with a greater than 50 percent reduction in accidents for the targeted intersections.

Designing for prevailing conditions is critical. There is a irrefutable symbiotic relationship between the public’s consensus as to what speed is reasonable and prudent (85-90th percentile of free flowing traffic - safest speed) and ensuring that all traffic control devices are set to safely manage the flow for the speed as found for a particular location.

In all studies, designing for prevailing conditions has been shown to be the most effective practice in reducing accident rates. This is particularly true for signal timing, speed limits, channelization, guidance and hazard warnings. Title 23 entrusted these decisions SOLELY to engineers applying the body of knowledge amassed by their institutions. This is a national standard where all traffic control in the nation has the same appearance; expectation and application using only verified nationally recognized practices; as opposed to 50,000 entities each with their own conjecture, practices and applications. A Uniform National Standard to be applied equally regardless of state lines or jurisdiction.

Therefore since 1988, the role of political bodies is to administratively codify these best practices into law. A political body cannot make an engineering judgment, overrule an engineering finding or order a device installed without the concurrence of a licensed engineer - that this installation is in accord with national standards or warrants. But they can direct the engineer to make sure these best practices are followed, not minimized.

Under the law a Political entity may ask for another alternative but any alternative must also be in accordance with the prescribed practices. Even if a device meets minimum MUTCD statutory requirements, it “shall not be a legal requirement for their installation.” Using engineering judgment as to the best overall solution, the engineer may choose not to install it. This is particularly true of stop signs, unwarranted signals and mid-block cross walks. Again, the law says it’s SOLELY their choice. However, if installed, they shall meet that particular device’s MUTCD provisions.

The governing federal law, Title 23 and its MUTCD is a unique and ironic twist on federal government preemption. The drafters four decades ago knew that safety is best served when the actual road being regulated is reviewed taking into account all factors and that remains today an indisputable fact and best practice. Traffic engineering studies are the cornerstone of basis-in-fact findings as to what traffic control devices or safety mitigation may be warranted. Without a proper study, all traffic control is based on unfounded conjecture, and safety is compromised.

This Federal law says according to LOCAL conditions, after the LOCAL engineers have personally determined how the LOCAL people who use that particular section of LOCAL roadway on a daily basis are driving and they have reviewed the LOCAL highway facilities, traffic volumes, existing traffic control devices and accident data or any notices of defect. Then the engineers’ are directed to apply only nationally accepted and verified sound engineering practices to remedy any problems and best manage the flow for the conditions found, NOT conjecture from Washington, State Capitals, Local Politicians or Traffic Committees of lay persons or the personal opinions of the engineers themselves. If they have an idea on how to improve practices, there is a process to obtain permission to experiment with their thesis.

From a Safety Perspective, Compliance is the Only Best Practice!

Starting with the number one question. If within engineering practices compliance and safety can be obtained with proper engineering and signal timing, then why isn’t it?

What we know for sure, an intersection’s safety is determined by the actions of the engineer applying verified best practice that attains compliance; not conjecture, myth, cameras or police officers.

Signalized intersections are not a safety panacea, they reduce the capacity of a roadway, cause traffic delays, often create a bigger problem than they solve, increase air pollution and should not be installed if alternative engineering solutions are available and unless all warrants are met. They should be removed or disabled when they no longer are warranted or could be replaced with less intrusive engineering solutions.

Yellow Interval: The period of time allotted for all motorists and commercial vehicles to make a decision to go or not to go and to stop or proceed in a calm and orderly fashion. Codified parameters: 3-6 seconds

The 3 second yellow interval has very limited application: entry from parking structures and other locations where the traffic generally has no inherent momentum, a feeder location with slow moving traffic. Note: slow moving vehicles can be very dangerous therefore the intersection clearance intervals (yellow and all red) must accommodate their needs.

Even minor changes in yellow interval timing can significantly increase compliance thereby reducing unsafe entries on red. Moreover, the cameras have documented motorists do not abuse increased yellow; no rebound in violations and compliance is maintained. (1980 ITE research, same conclusion)

One expert in the field found that a 5.5 second yellow interval default setting provides the best overall compliance. And if improved system efficiency is desired, the yellow interval should only be reduced to whatever level compliance can be maintained (97-99th percentile). The only exception, when the prevailing speed is in excess of 50 mph, then the yellow interval must be set at 6 seconds.

As for the 4 second proposed minimum camera intersections, if it doesn’t meet the traffic's needs it too is inadequate and doesn’t solve the larger question. A 4 second yellow is no less an enforcement trap if the traffic's needs are greater.

There is a statistical curve of probability around the average time a driver needs to respond to a yellow signal, and the goal is to make sure that virtually ALL of the curve is accommodated before the opposing signal turns green. If it takes 6 seconds of yellow to get all the traffic stopped, including heavy vehicles, buses with standees, old people, distracted drivers, drivers with poor vision, in all lighting conditions, then that is what it takes, and there's nothing anyone can do about it. Thus the foundation for the statutory federal safety standard that the yellow interval SHALL meet the traffic’s needs.

All Red Phase: The all red is an additional safety buffer to ensure that all expected traffic that may enter the intersection has cleared prior to giving the conflicting traffic the safe to enter green. Codified parameters: Should not exceed 6 seconds.

Should not exceed 6 seconds? Yes it may be lengthened as much as required because there are instances where longer all reds have been warranted. Large intersections where traffic takes a long time to clear particularly slow moving vehicle (busses, trucks etc.), on higher speeds roads with commercial traffic, extreme grades where heavy trucks are present (gravel/logging trucks etc. going down hill) and on higher speed sections 2 seconds should be an absolute minimum for through traffic prior to giving the green to conflicting cross traffic. And if accidents continue it should be lengthened. This is a safety tool in the regulations, an important one that is meant to be used, it does save lives, use it.

In contrast, you have the scary statement of the engineering department that they use a system wide 1 second all red. Totally inadequate for higher speeds roadways or hills … then add this to their minimalist practice where by design the yellow does not meet the needs of a large percentage of the vehicles, and you wonder why you have high accident rates?

Compliance and safety is further improved when signals are synchronized, flow or sight distance obstructions are corrected, channelization is improved, lamp size increased for better visibility, green duration is sufficient to clear traffic, and when signal changes are marked in advance when they are not readily apparent because of curves, hills or high approach speeds etc. And the intersection accident history is examined for possible contributing engineering shortcomings. In all cases the results need to be plotted, documented and be part of the basis for establishing yellow on the light as well as the all red safety clearance setting.

If there are large numbers of violations or accidents, try another prescribed countermeasure until they are all but eliminated. In signal timing, this may mean only a small incremental increase in yellow duration or synchronization of the signals or an increase in the all red clearance cushion or new signal heads that are distinct from the background or an increase in lamp size or new delineation or pre warning signs or all. What we know for sure is that the cameras do not solve any of these problems and in most cases they have actually increased accident rates.

There is no middle ground here. If safety is your concern, sound engineering practice properly applied can and do reduce accident rates. The tools are there. Yellow interval timing is one of them. Use it. How much? Whatever it takes to accommodate the traffics needs! If you choose to maintain inadequate yellow clearance intervals, that's your choice but you surely can't blame motorists for your actions.

Observations

Intersection Safety/Traffic Needs Study: If you really have a problem intersection and would like to do a study to really nail down what the problems really are there is a solution. Nestor, a red light camera vendor has a program where they will come and set up video cameras at all an intersection’s approaches. This data is collected for a 24-hour period to be reviewed later. Upon review all the problems become apparent including the source and number of violations. This process also tracts entries on red and records how long after onset of red they occurred and the time it takes traffic to clear. Therefore this data could be used to become the basis for the intersections timing needs. These studies cost about 5-7,000 dollars per intersection.

Safety Benefit of Cameras: In every so called US study or safety audit regarding red light cameras the cameras are given credit for all and any reductions, regardless of true source. When yellow was lengthened and red light violations dropped - cameras given credit. When signals are synchronized - cameras given credit. When signal heads were changed, new channelization and other physical improvements - cameras given credit. Laws changed tripling fines - cameras given credit. Public awareness campaigns - cameras given credit. Then you have Oxnard California’s study done by the Insurance Institute for Highway Safety (Richard Retting), they reported lower accidents because of the cameras but as it turns out, they didn’t actually study the intersection they reported on nor the cause of the accidents their either. Whereas the Australian study and others have shown net increases and violations levels that continue unabated until engineering counter measures are applied, exactly the same as San Diego’s experience.

San Diego Accident Data: Staff is reporting increases in accidents at the red light intersections since the cameras have been turned off? Interesting to say the least because San Diego PD no longer takes accident reports. Moreover there are natural deviations in rates and only those studies that cover large numbers and time spans can be considered valid. Same location could have 4 in one month and zero for the next three for no apparent reason whatsoever – and it does happen. Therefore quoting these numbers by either side when the quantity is unknown is meaningless.

The Engineering Department’s Proposed Practice: Makes no sense! The engineering study they described was not an intersection safety review and needs analysis (engineering study) that has been required by law since 1988. Instead it amounted to a cursory review and what engineering they spoke of was for the cameras installation, not a prescribed safety action plan. The incredulous part of this, their plan had no provisions to see if the safety improvements worked … they intended to place the cameras regardless – immediately. Worse yet, what engineering standards and practices they claimed they were going to use will never meet the traffic needs. Thereby leaving their inherent unsafe conditions in place causing untold unnecessary injuries and deaths in perpetuity, except now you have pictures to remember them by.

Other Notable Unsafe Practices: Besides poor signal timing, unwise use of traffic control devices, and unmarked hazards San Diego’s roadway hazard mitigation appears to be virtually nonexistent. Again where required, you meet the minimum requirements but completely miss the main point of the objective. Leaving San Diego with thousands of hazards that would and do have the same effect as the unprotected columns that killed Princes Di. - READ LANDSCAPING.

Great illustrations: You have breakaway bus stop sign post installed on a major arterial in Escondido (9th Avenue/Auto Parkway), yet the city placed 2-5,000 pound granite rocks at the intersection and in the median for the esthetic affect. You have breakaway no parking signs on an arterial (Bernardo Heights Parkway), a street lined with 6-8 inch diameter trees. You’re not alone, in Riverside County this weekend I was on a newly widened 6 lane arterial with traffic speeds of up to and greater than 60 miles per hour, sporting more than a hundred freshly planted 12-18 diameter palms in the median, only feet from the travel lanes.

On the Bernardo Heights Parkway example you can see the scars on the trees from significant impacts, and the other morning I noticed yellow tape around an accident scene. You know why they close an area don't you, probably another unnecessary death!

We know hazard removal and mitigation works extremely well and has literally saved thousands of lives. Why did we exempt cities, counties et al. Why do we allow direct exposure to granite boulders and large trees on our streets. With forethought, landscaping can supply both the beauty and be safe too.

Another “WHY” this safety law is in place from the hearing: That San Diego doesn’t follow. During the hearing one Council member talked about the process citizens use to get stop signs installed, mentioning that many times it is against the advice of the engineer. The sad part, more often than not children under 12 and the elderly are the primary victims of these acts. That in part is why it is illegal under Title 23 to overrule the engineer’s professional judgment. Moreover, traffic calming, unwarranted stop and many other such efforts have been documented to actually increase accident rates and congestion both, and in one federal study they documented an astonishing 46 percent increase in air pollutants. Those jurisdictions that are removing every unwarranted stop sign and replacing others with yield signs have seen dramatic improvements in flow, reduced accidents and pollution.

Conclusion:

The solution is there, start with a longer yellow and only reduce it to a level where safety and compliance can be maintained, then provide an adequate all red phase to meet the safety needs of that intersection. In the process you must abandon altogether the always-inadequate minimalist approach to signal timing. And to reduce accidents, once a problem intersection is identified all engineering solutions must be tried and then tested to see if they worked before any thought should be given to a camera.

Quotable Truisms, email by, B. Michel, Re: Red Light Cameras and Safety,

“If you are at all familiar with industrial practices you will recognize the truism that “You can’t inspect quality into your product. It must be designed in.” If safe streets are your product, then enforcement is your inspection. I maintain that properly designed and engineered speed limits and signal timings are the right long term solution.”

Cameras and red light enforcement teams become a moot point if the engineering is done correctly in the first place. No matter how you look at it, where a camera is financially viable or officers are able to write large numbers of citations on an ongoing basis, it represents an uncorrected safety defect that could be corrected. All accidents are not preventable, but not acting on those that are preventable is something else altogether.

What San Diego needs is an engineer who champions best practices … and more importantly knows what they are. The question really is where are the problems and what can we do about them, not what are the minimum requirements. For safety, fair laws, less pollution and more efficiency out of our roadways, engineering will always be the best solution for all. There are no substitutes or short cuts. The cameras do nothing more than turn poor engineering practices and safety defects that are injuring and killing your citizens into a revenue source.