Review 2009 Proposed MUTCD

Bob Wagar -- Northwest Engineers.

Seattle, Washington 98134

Chapters 5-10

Page 932 Lines 22-27 Change was made in the 2000 MUTCD to require use of
STOP and YIELD AHEAD signs. Prior to that time it was support statement
"intended for use" Not sure of potential liability for agencies, but it
would appear that vehicles parking on residential streets 20 feet back
from STOP or YIELD could require usage of advance warning. Not opposed
to this, but believe much work should be done with state and local
agencies to make sure they understand this requirement.

Page 937 Lines 40-43 Supplemental plaques required for R/R advance.
Seems like waste of signs.

Page 938 Lines 4-7 Requires STOP or YIELD at low volume highway-rail
grade crossing that are not equipped with automatic traffic control
devises." Based on current YIELD sign criteria majority of these
crossing would require STOP, and I believe would be disregarded by
overwhelming majority of users. This goes directly against the basic
requirement for all traffic control devices of "commanding respect of
users".

Page 959 Line 22 "For daytime and nighttime activity," is this needed.
If STANDARD applies at all times why do you need to state daytime and
nighttime. Shouldn't sentence start with: "Flaggers shall wear" etc.

Page 965 Line 47 Reference to Table 6E-1. Tables 6C-2 and Table 6E-1 are
exactly the same. I would think that Table 6E-1 could be eliminated and
reference on line 47 changed to Table 6C-2. Are two Tables with very
same information needed?

Page 968 Line 22 Metric conversion 60 km/h (35 mph)

Line 30 Reference to "Standard Highway Sign and Markings" when will new
book be out. I assume it will be available on line, as it is currently.
Confirmation please.

Page 970 Line 16 "Signs that have lost significant legibility shall be
promptly replaced."

Is definition needed of "significant legibility" is term to subjective?

I understand intent, but question if this causes liability problem.

Page 975 Lines 33-37 NEW TRAFFIC PATTERN AHEAD signs. Not as good as
signs currently being used within State of Washington. Specifying this
sign could cause agencies to use instead of better, more informative
signs. (See comments in Chapter 2).

Page 982 "Messages on an electronic Portable Changeable Message sign
**[shall consist of no more than two phases"]{.underline}** ***[I
STRONGLY DISAGREE!]{.underline}*** Page 983 Lines 27-28 "If more than
two phases are needed to display a message, additional Portable
Changeable Message signs **[should be used."]{.underline}** There are
many times where three phases are needed. Page 982 Line 50 needs to have
"shall" replaced with "should", so that agencies can use three phase
messages when necessary. PCMS are visible for 800 feet, Page 983 calls
for separating two PCMS by 500 feet. Wouldn't that cause great confusion
for approaching drivers if they have two PCMS that can both be read at
the same time? Line 1 and 2 on Page 983 address when two signs are
visible, and indicates only one of signs shall display a sequential
message at any given time. So if you have three phase message the first
board would show Phase one for two seconds and Phase two for two
seconds, during that time there would be no display on second PCMS.
After 4 second of Phases 1 and 2, the second PCMS would display phase 3.
This seems much more confusing to me then allowing three phases to be
displayed on one PCMS. As indicated in previous comments, three phase
messages can be displayed on a single PCMS for speeds up to 45 MPH and
allow viewing of entire messages twice. (45 mph x 1.47 fps x 12 seconds
= 793.8 feet).

Channelizing Devices;

Page 987 Lines 47 and 48 calls out white banding , Line 51 orange and
white; Page 988 line 5 (in part) say Traffic cones may be used to divide
opposing vehicular traffic lanes.

Same applies to Tubular markers, vertical panels, Drums and Class 1
Barricades. All can be used to separate opposite direction of travel
lanes. Chapter 3F Page 833 Lines 19-22 Standard "Except for the bands on
channelizing devices that are used to separate traffic flows in opposing
directions, the color of the retroreflective bands on channelizing
devices shall be white. The **bands on channelizing devices that are
used to separate traffic flows in opposing directions [shall be
yellow."]{.underline}**

Within Chapter 3, I indicated my concern for using yellow banding to
separate opposing directions of travel. If yellow is to replace white
for opposite directions of travel, references on pages 987 through 990
will need to be modified to allow yellow banding. I still believe this
will cause major maintenance problems and potential liability problems.
I also would question color contract between yellow/orange versus
white/orange

Page 1003 Section 6F.85 Screens Curious why this was removed from MUTCD
-- No explanation provided.

Page 1014 Line 7 Metric conversion 60km/h (40 mph)?

# March 13, 2008\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ 

Chapter 7 Schools

Page 1072 References "Standard Highway Signs and Markings" When will it
be available?

Page 1073 School Warning sign requirement for FYG. 10 year compliance,
should be adequate.

Page 1074 Lines 32-37 Allows posting on School signs when location is
within 125 feet on side street. Could same principle be applied to trail
crossings?

Page 1075 Line 29-41 Use of Table 2C-4, column "0" Condition B **[is
wrong]{.underline}**. Does not provide adequate stopping sight distance
for speeds. If Table is to be referenced it should be Table 6C-2.
(duplicate of 6E-1, not needed).

Page 1076 Line 1 School zone 200 feet from crosswalk, Washington State
300 feet. Modification may be needed.

Lines 7-10 School Speed Limit assembly. Many local jurisdictions within
Washington State are using bottom plaques that state "WHEN FLASHING OR
WHEN CHILDREN ARE PRESENT". This seems reasonable to me, but does it
violate MUTCD STANDARD "and a bottom plaque (S4-1P, S4-2P, S4-4)or
S4-6P)".? I would like to see something that expressly allows for use of
two plaques, or two messages allowed on a single plaque.

Page 1077 Lines 1-5 Requires both END SCHOOL ZONE and a speed limit
sign. I have seen smaller version of "End School Zone" posted with a
standard speed limit sign in King County Washington, that look very
good. Consider reducing the size of the S5-2 when used with standard
speed limit sign. If "WHEN CHILDREN ARE PRESENT" can be placed on S4-2P,
I would think "End School Zone" would fit on same size sign. As an
alternate, maybe one sign with "End School Zone / Speed Limit \_\_"
should be developed.

Page 1079 Lines 7-8. "and the spacing should not exceed 2.5 time the
line width" add "pattern" at end of sentence. Many jurisdiction using 8
inch line, 8 inch gap and another 8 inch line to mark crosswalk, for 24
inch pattern.

Page 1083 Lines 47-49 Adult crossing guards shall wear high-visibility
retroreflective safety apparel. Two year compliance date. (changed from
5 years in 2003). There needs to be information on this getting out to
School Districts. I am still seeing many Adult crossing guards without
proper safety apparel.

Page 1084 Lines 6-13 New standard, without compliance date for required
use of STOP paddle for adult crossing guards. Since no compliance date
is set, I understand that this standard will take effect two years after
Final Rule. This along with previous safety apparel requirements needs
to get out to school districts, so that they can take action to meet
this new requirements.

# March 13, 2008\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Chapter 8

Page 1088 line 18 change centerline to center line.

Page 1092 Railroad Crossbuck sign. Requirements for retroreflective
material. Within my state these signs are maintained by the railroad.
Any requirement for retroreflective material needs to be brought to
railroads attention, for installation and maintenance. Agencies should
not be placing material on Railroad signs. (this would also apply to
proposed STOP and YIELD to be placed on crossbuck signs, (Page 1093)

Page 1093 Line 34-51 New STANDARD for Yield or Stop at all passive
highway rail grade crossing. 5 year compliance. Warrant for YIELD still
unclear, based on current standards (85%, posted, statutory), with
existing compliance date of January 17, 2011.

I have concern whether these signs, if placed, will "command respect" of
roadway users. Placing signs that do not command respect is poor
engineering practice. I would be very interested in seeing what agencies
think about this new requirement.

It is interesting that FHWA has made statement (Page 1093 lines 39-42)
regarding use of STOP signs "can result in a high rate of non-compliance
by road users".

Page 1094 Lines 6-17 Standard: Stop or Yield to be placed on Crossbuck
Assembly, or if placed separately is considered to be a part of the
Crossbuck Assembly. This would indicate that the Railroad would be
responsible for this signing within my state. Are the railroads prepared
to install and maintain this signing at passive crossings? Clarification
of responsibility for both the installation and ongoing maintenance of
these signs is needed.

Page 1095 Line 15 "If a yield line is used, it should be a transverse
line at a right angle to the traveled way" Seems like Yield line marking
should be referenced to Figure 3b-14 for proper layout. It is not a
transverse line but a series of triangles, per Section 3B.16.

Line 30-34 Requires either NO Signal or Signal Ahead to be added to all
W10-1's. Two more signs added, question value of these signs. Are they
really needed?

Page 1097-1098 Emergency Notification Sign. Guidance : Responsibility
for these signs should be identified as Railroad. Local and State
agencies should not be responsible for either installation or
maintenance of these signs.

Page 1099 Lines 1-3 deleted :as a supplemental plaque on the Crossbuck"
and indicated on a separate post in the immediate vicinity of the
highway-rail crossing on the railroad right-of-way." I don't like this
sign, I don't think it is logical as a stand alone sign, and fell it
misses the basic concept of a regulatory sign, as identified in Section
2A.05 A "Regulatory signs give notice of traffic laws or regulations".
If these signs are used on placed on railroad right-of-way, are they to
be installed and maintained by railroad?

Page 1100 Line 23 Guidance "When pavement markings re used the center of
the X symbol should be directly in line with the Advance Warning sign."
This was changed When used, a portion of the pavement marking symbol
should be directly opposite the Advance Warning Sign. This allow
placement of the W10-1 within a 50 foot area of the advance markings.
Stating is should be opposite the center of the X is to restrictive.
Note that Figure 8B-7 still has old wording, which I believe is much
better then the proposed change.

Page 1104 Line 13 Gate arms Change from 45 degree diagonal to vertical
stripes. 10 year compliance. Need to advise railroad is need to make
this change. This could be easy to overlook.

# March 13, 2008\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Chapter 9

Page 1120 Lines 7-8 A TRAIL XING (W11-15P) supplemental plaque (see
Figure 9B-3 may be mounted below the W11-15 sign. Plaque should be allow
to be placed either **[above]{.underline}** or below the W11-15 sign.

Page 1127 Line 12 50 km/h or 35 mph Metric conversion?

Line 24-25 If used, the Shared Lane Marking should be placed immediately
after an intersection and spaced at intervals not greater that 75m (250
ft) thereafter. Seems like calling out 250 feet is excessive. Would
prefer wording that says "at appropriate spacing, as determined by
engineering review" or similar. Don't pin down to 250 feet. Let
engineers decide what spacing is appropriate.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Chapter 10

Page 1134 Lines 19-24 LOOK sign now calls for on separate post on the
light rail transit right-of-way. Identify responsibility for placement
and maintenance. Still feel very poor sign. Question basis for
Regulatory (what law dose is reference). Look where at what?

Page 1140 Line 32-33 "the center of the X symbol should be directly in
line with the Advance Warning sign . Placement to restrictive. Old
wording and that shown on Figure 8B-7 is much better. Allows placement
of sign within 50 area of advance markings.

Page 1142 Line 15-18 Changes from Option to Standard requirement for
audible devices and has 5 year compliance period. Not sure what impact
this may have on agencies, but any change form option to standard places
new burden on state and local agencies. Is 5 years sufficient for
compliance period? Using 10 years for countdown on ped signals.

Page 1153 Line 17 change centerline to center line.