June 26, 2008

Dockets Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE.

Washington, DC 20590

Subject: Proposed Changes to the MUTCD, Docket No. FHWA-2007-28977

Dear FHWA:

The Juan Bautista de Anza National Historic Trail has strong concerns
about proposed changes to the Manual of Uniform Traffic Control Devices
(MUTCD). Specifically, we are concerned about Section 21.08, Trail Signs
which places a blanket prohibition on all trail signs. The Anza Trail
relies on highway signs as an integral component of our auto tour route.
This route is associated with our brochure and detailed information on
specific highways and historic sites can be found on our web site
([www.nps.gov/juba](http://www.nps.gov/juba)). Auto tour route signs are
needed to assure Anza Trail drivers that they are on the correct highway
and to designate where the route changes. In no cases is there anything
more on the sign than the Anza Trail logo, the word "Historic Route" or
"Auto Tour Route" in large bold letters, and, where the route changes,
an arrow below the sign. There is no type of interpretive information on
the signs and no reason for anyone to stop at a posted sign. The auto
tour route signs have been on highways in California for over five years
and we have not heard of any incidents where they have been a hazard to
traffic or traffic flow.

The National Park Service has almost 40 years' experience administering
components of the National Trails System. These trails are created by
Congress under authorities of the National Trails System Act, as amended
(16 USC 1241-1251). Today, under this Act, Congress has created eight
national scenic trails and 17 national historic trails

Specifically in Section 7(c), that act authorizes that the secretaries
of the Interior and Agriculture

> *. . . in consultation with appropriate governmental agencies and
> public and private organizations, shall establish a uniform marker,
> including thereon an appropriate and distinctive symbol for each
> national recreation, national scenic, and national historic trail.*

That section goes on to state:

> *Where a national historic trail follows existing public roads,
> developed rights‑of‑way or waterways, and similar features of man\'s
> nonhistorically related development, approximating the original
> location of a historic route, such segments may be marked to
> facilitate retracement of the historic route, and where a national
> historic trail parallels an existing public road, such road may be
> marked to commemorate the historic route.*

In recent years, two other documents -- both of which involve both the
Federal Highway Administration and the National Park Service \-- have
been crafted to foster interagency collaboration in support of the
National Trails System and its components. The first is Executive Order
13195, *Trails for America in the 21^st^ Century*, signed January 18,
2001. It's most relevant passage for this discussion is Section 1, which
reads in part:

> *Federal Agency Duties. Federal agencies will, to the extent permitted
> by law and where practicable -- and in conjunction with Tribes,
> States, local governments, and interested citizen groups -- protect,
> connect, promote, and assist trails of all types throughout the United
> States. This will be accomplished by . . .*
>
> *(c) Coordinating maps and data for the components of the national
> trails system and Millennium Trails network to ensure that these
> trails are connected into a national system and that they benefit from
> appropriate national programs . . .*

The second is an agreement specific to the National Trails System. In
2006, NPS and FHWA were joined by the USDA Forest Service, the Bureau of
Land Management, the Fish & Wildlife Service, and the U.S. Army Corps of
Engineers in signing the 10-year *National Trails System Memorandum of
Understanding*. Under the section titled "Purposes and Principles," the
most relevant paragraph states:

> ***D. Recreational Opportunities and Visitor Satisfaction** \-- The
> agencies shall strive to provide visitors to National Trails with
> opportunities for an enjoyable and memorable trail experience. The
> agencies shall work together to ensure that their jurisdictional
> boundaries are not viewed as impediments to quality recreational
> opportunities and services. National Trails serve communities best
> when they integrate recreational, health, environmental, cultural,
> economic, and transportation objectives.*

Together the Trails Act and these subsequent orders and agreements
suggest that both NPS and FHWA should do everything they can to foster
appropriate wayfinding markings for national trails rather than prohibit
them from Federally-assisted highways and freeways.

The removal of Anza Trail auto tour signs in California and the
inability to place signs in Arizona will have a significant negative
impact on the Anza Trail identity and our ability to enact a full
compliment of Anza Trail programs. As well, many of our federal, tribal,
county and city government and nonprofit partners recognize the Anza
Trail auto tour route as a positive economic benefit, especially within
the tourism sector. The Anza Trail has always been a bottom-up,
community oriented program of the National Park Service. Without a
marked auto tour route as the backbone of the Anza trail many of the
Anza Trail programs established with historic and recreational sites and
institutions will suffer.

Therefore, we respectfully request that any prohibition of National
Historic Trail or National Scenic Trail auto tour route signs be removed
from Section 21.08, Trail Signs. We will continue to work with federal
and state highway agencies to assure that auto tour route signs are
installed and located in a manner consistent with the safety needs of
the driving public.

Thank you for this opportunity to comment on proposed changes to the
MUTCD. If I can provide further comments or any information concerning
the Anza Trail please feel free to contact me.

Sincerely,

Stanley C. Bond, Jr., Ph.D.

Superintendent