**Comments on the Notice of Proposed Amendment of the Manual of Uniform
Traffic Control Devices.**

**FHWA-2007-28977-0001**

**Submission from the League of American Bicyclists**

**Submitted by Andy Clarke, President**

General Notes:

The term \"motorist\" is used dozens of times throughout the Manual;
however, in nearly all cases, the situation is also applicable or useful
to other classes of road users, such as bicyclists and in many cases
pedestrians. The use of the term \"motorist\" carries an implicit
message that the devices in question serve only the needs of motor
vehicles and their operators, or that nonmotorized users are not
accepted or intended users of the transportation system. This wording
seems excessively discriminatory and is misleading to MUTCD users and
practitioners. Use \"motorist\" only in sections that refer exclusively
to operators of motor vehicles, such as devices used solely on those few
roads prohibited to nonmotorized travel. Change all other instances of
the term \"motorist\" to \"traveler\" (which includes pedestrians and
drivers of motorized and nonmotorized vehicles), \"driver\" (which
encompasses all vehicle operators, including bicyclists), or other
suitable term.

Introduction -

No comments.

Part 1 -

No comments.

Part 2 -

Section 2B.04 Right-of-Way at Intersections, pages 626-627:

LAB recommends adding a note directing users to refer to Section 9B.03
for assignment of priority for path-roadway intersections.

Section 2B.09 YIELD Sign Applications:

The League agrees with the proposed wording. This change will help to
start slowing the overproliferation of STOP signs across the US, which
could provide real improvements in operations, efficiency, & safety,
especially for bicycle travel. However, additional specific action may
be needed by FHWA to encourage agencies to use more appropriate and less
restrictive traffic control at intersections.

Section 2B.26 Regulatory Signs for Preferential Lanes -- General, page
641, lines 36-38:

In many situations, bicycle lanes are not occupied exclusively by
bicyclists. For example, approaching an intersection, Part 9 of the
MUTCD allows bike lanes to be dashed to encourage turning vehicles to
merge to the far right into the bike lane to prevent unexpected
conflicts between turning vehicles and straight-through bicyclists at
the intersection. The League recommends deleting the word
\"exclusively\"

in line 36.

Section 2B.46 Selective Exclusion Signs, page 656, lines 25-34:

LAB recommends adding the new R9-13 & R9-14 signs to the list in this
Support statement.

Section 2B.59 Traffic Signal Signs (R10-1 through R10-32P):

See comments on Figure 2B-29.

Section 2B.59 Traffic Signal Signs (R10-1 through R10-32P), page 664, 0D
lines 35-36:

The term \"special bicycle phase\" is undefined, and could be
misunderstood. LAB recommends rephrasing this statement as \"The R10-24
or R10-26 sign (see Section 9B.11) may be used where a pushbutton
detector has been installed exclusively for bicyclists to actuate a
green phase for bicyclists\". This also covers any special phases, as
they would be some sort of green.

Section 2C.51 Vehicular Traffic Signs (W8-6, W11-1, W11-5, W11-5a,
W11-8, W11-10, W11-11, W11-12P, W11-14, and W11-15), page 688, lines
12-15:

See comments on Figure 2C-11 regarding design of the W11-15 sign.

Part 2 - Tables

LAB recommends the following changes to the proposed tables:

Table 2B-1:

\- Change minimum size of R5-6 to 18\" x 18\" for consistency with the
similar R9-3 sign.

\- Add R9-13, R9-14 signs to table, with same sizes as shown for the

R9-3 sign.

Part 2 - Figures

LAB recommends the following changes to the proposed figures:

Figure 2B-14:

\- R9-13 & R9-14 should be included in either this figure or in Figure
2B-29.

Figure 2B-29:

\- R9-13 & R9-14 should be included in either this figure or in Figure
2B-14.

\- The Canadian \"finger symbol\" could provide an unintended
directional message, which could likely conflict with arrows on the
sign, or be mistaken for an arrow. Note that on the R10-3 and R10-3a
shown in the figure, the finger points in the opposite direction from
the arrows, 0D and at first glance a reader might interpret the
directionality of the sign completely opposite from what was intended.
LAB recommends that the \"finger\" always point in the direction of any
arrows on the sign.

Figure 2C-11:

\- W11-15: The bicycle symbol shown (bike with rider) is not a standard
bicycle symbol adopted by FHWA. The superimposition of symbols (such as
this) changes the meaning of the symbols, and can create opportunities
for misinterpretation. Recent research by the NCUTCD Bicycle Technical
Committee indicated that this design is not well understood by test
subjects as compared to other designs. The League recommends that a
different sign be used for this design (see additional comments in Part
9).

Figures 2J-5 through 2J-11:

The RS-066 Bicycle sign uses a symbol that is not consistent or uniform
with the bicycle symbol used elsewhere in the MUTCD. LAB recommends
using the standard bicycle symbol for this sign.

Part 3 -

Section 3B.07 Warrants for Use of Edge Lines, page 808, lines 27-29:

The League strongly supports the proposed changes regarding bicycle
lanes and edge lines.

Section 3B.13 Raised Pavement Markers Supplementing Other Markings, page
812, lines 6-7:

The League does not believe that raised pavement markers are appropriate
on edge lines, and fully concurs with the wording in Section 3B.13
(carried over from the 2003 MUTCD) recommending against the use of
raised pavement markers on edgelines. LAB strongly disagrees with any
effort or suggestion by any person or organization that this Guidance
statement or provision be modified or deleted.

Chapter 3H - Rumble Strip Markings: This new chapter seems to define
rumble strips as traffic control devices, which could have very negative
implications for bicyclists. LAB opposes the inclusion of this new
chapter.

Part 4 -

Section 4B.05 Adequate Roadway Capacity, page 843, lines 15-17:

As currently worded, this new paragraph could encourage agencies to make
striping changes that could negatively affect bicyclists, such as trying
to fit in very-narrow lanes or eliminate bike lanes or shared lanes.
Recommend adding a clarifying statement to address this concern, such
as: \"Consideration should also be given to the needs of bicyclists at
intersections, and to any impacts that changes to markings and lane
assignments will have on bicycle travel.\"

Section 4C.05 Warrant 4, Pedestrian Volume:

The League fully supports the revisions to this warrant, as they address
the need for higher-volume path-roadway intersections to use
signalization, and now apply more appropriate traffic and path user
volumes for this warrant. Howeve, LAB requests that FHWA modify the
wording in this section to clarify that at path-roadway intersections
analyzed under this warrant, bicyclist volumes should be included in all
counts and applied to all appropriate warrants.

Chapter 4F, Pedestrian Hybrid Signals:

The League fully supports this new chapter, as it provides a new yet
well-tested device that can be very useful at appropriate path-roadway
intersections.

Part 5 -

No comments.

Part 6 -

Figures 6I-6, 6I-15, 6I-16, 6I-26, and 6I-43: The 10 ft minimum width
requirement added to these figures does provide a minimum lane width for
these operations, which was not provided before. However, the added
wording by itself fails to address the impact of such narrow lanes on
bicycle travel, especially on higher-speed roadways. In these locations,
the travel lane is clearly too narrow for a motor vehicle and a bicycle
to travel side by side or to pass one another within that lane with
adequate clearances for safe operation. The League strongly recommends
that a statement be added to each figure that shows a 10 ft minimum lane
width that reminds MUTCD users to consider bicyclists in these temporary
traffic control areas. LAB also strongly recommends that all these
figures show the use of the R4-11 Bikes May Use Full Lane sign if lane
widths are 14 ft or less and no shoulder, bike lane, or other suitable
roadway area is present.

Part 7 -

No comments.

Part 8 -

No comments.

Part 9 -

The League fully supports and endorses the content of the proposed Part

9 of the MUTCD, with the following exceptions:

Section 9B.02 Design of Bicycle Signs,20page 1116, line 38 - add \"and
plaques\" after \"of bicycle signs\" for consistency with the wording
used elsewhere in Section 9B.02.

Section 9B.05 BEGIN RIGHT TURN LANE YIELD TO BIKES Sign (R4-4), page
1117, line 29 - add \"Figure 9C-4\" after \"(see Figures 9C-1 and
9C-3)\", since Figure 9C-4 also shows the R4-4 sign.

Section 9B.09 Selective Exclusion Signs, page 1118, line 16 - delete the
phrase \"Where authorized by public officials under State or local
statutes or ordinances\", since this is adequately covered in Part 1.

Section 9B.09 Selective Exclusion Signs, page 1118, line 16 - add \"(see
Figure 9B-2)\" after \"Selective Exclusion signs\".

Section 9B.09 Selective Exclusion Signs, page 1118, lines 21-29 - Delete
the entire Guidance section and replace with the following Support
statement, which is consistent with the presentation of Selective
Exclusion signs in Section 2B.46:

Support:

Typical exclusion messages include:

No Bicycles (R5-6)

No Pedestrians (R9-3a)

No Skaters (R9-13)

No Equestrians (R9-14)

Note: The R9-13 and R9-14 should also be included in Section 2B.46 and
Figure 2B-14, since these signs can also be used on roadways without
bicycle facilities.

Section 9B.11 Bicycle Regulatory Signs, page 1119, lines 1-2 - Add \"or
other warning lights or beacons\" before \"have been provided\" to allow
the use of the R10-25 sign in other appropriate locations where other
types of beacons or lights are used for traffic control for bicyclists,
such as beacons at path-roadway crossings, tunnels, or other locations.

Section 9B.18 Bicycle Warning and Combined Bicycle/Pedestrian Signs

(W11-1 and W11-15): In human factors testing commissioned by NCUTCD, the
selected W11-15 sign symbol design depicted in the proposed MUTCD tested
poorly as compared to other alternative sign designs. See comments on
Figure 9B-3.

Section 9B.24 Reference Location Signs (D10-1 through D10-3) and
Intermediate Reference Location Signs (D10-1a through D10-3a), page
1123, line 32 - Delete the \"Zero distance should begin at the south and
west terminus points of shared-use paths\" Guidance statement, as it
does not allow for needed flexibility for local agencies in setting up
reference marker systems on paths.

Section 9B.26 Object Markers: Add pictures of each type of object marker
to a figure (existing or new) in Chapter 9B, similar to how object
markers were depicted in prior editions of Part 9 of the MUTCD.

Also consider Including a proportionately smaller (6\" x 18\") version
of the Type III object marker for use on shared-use paths. This smaller
size would be more useful and appropriate than the standard 12\" x 36\"
size for many applications, and will provide adequate visibility and
target value at pathway speeds.

Section 9C.03 Marking Patterns and Colors on Shared-Use Paths, page
1125, lines 40-41 - Delete the words \"traveling in the same
direction\".

This proposed change is unnecessary for shared-use path operations and
safety, and this change makes this statement inconsistent with normal
and typical use for this marking. Marked pedestrian areas on shared-use
paths are typically marked with a solid white line consistent with
Section 9C.03 in the 2003 MUTCD, but are not intended or marked as
directional facilities, as typical movement of pedestrian in these areas
is multidirectional. A directional restriction of movement in these
areas would likely have very poor user compliance, and create
discrepancies between user expectations and actual experience.

Section 9C.04 Markings for Bicycle Lanes, page 1126, lines 34-36 -
Delete the Option statement and replace with the following wording: \"If
the word or symbol pavement markings shown in Figure 9C-6 are used,
Bicycle Lane signs (see Section 9B.04) may also be used. To avoid
overuse of the signs, the signs need not be adjacent to every symbol.\"
This wording conveys the same information, but in a cleaner and more
comprehensible manner.

Section 9C.04 Markings for Bicycle Lanes, page 1126, line 38-39 - Delete
the words \"or other circular intersection\", since there are certain
types of larger circular intersections (such as ones with significant
distances between exits & entrances) where bike lanes may be appropriate
based on engineering judgment.

Section 9C.07 Shared Lane Marking

The League definitely endorses the addition of this section, and str
ongly urges its immediate adoption based 9n successful experimentation
and use across the US. If there is a delay in adopting a new edition of
the MUTCD, such as for a supplemental NPA, then LAB urges FHWA to issue
an Interim Approval for these markings to promote their use in
appropriate locations across the US.

Table 9B-1 -

1\. Sheet 1, table item 3 - Replace the term \"Bicycle Lane\" with
\"Bike

Lane\" to be consistent with the actual wording on the sign, and to be

consistent with Section 9B.04.

2\. Sheet 1, table item 3 - NCUTCD recommends a minimum roadway size for

the R3-17 sign of 24\" x 18\", not 30\" x 24\". The League supports

NCUTCD\'s recommendation. Given the intentionally simple and legible

design of the R3-17, the 24\" x 18\" size is entirely functional for all

road users, the size and scale of this sign is consistent with the

widely-used D11-1 BIKE ROUTE sign, and is the size actually used by

many jurisdictions in the US (notwithstanding the size currently called

for in the 2003 MUTCD). In fact, in Figure 9B-2 of the draft MUTCD, the

R3-17 is shown to scale at a 24\" x 18\" size, implying that it is
FHWA\'s

intent to implement this size as standard. The 30\" x 24\" size can
still

be optionally used if a larger sign size is occasionally warranted.

3\. Sheet 1, table item 4 - Replace the term \"Bicycle Lane Supplemental

Plaques\" with \"Bike Lane (plaques)\" to be consistent with the actual

wording on the R3-17, and to be consistent with Section 9B.04.

4\. Sheet 1, table item 4 - NCUTCD recommends a minimum roadway size for

the R3-17 plaques of 24\" x 8\", not 30\" x 12\". The League supports

NCUTCD\'s recommendation. Given the simple one-word design of the R3-17

plaques, the 24\" x 8\" size is entirely functional for all road users,

and is the size actually used by many jurisdictions in the US

(notwithstanding the size currently called for in the 2003 MUTCD). In

fact, in Figure 9B-2 of the draft MUTCD, the R3-17 plaques are shown to

scale at a 24\" x 8\" size, implying that it is FHWA\'s intent to

implement this size as standard. The 30\" x 12\" size can still be

optionally used if a larger sign size is occasionally warranted.

5\. Sheet 1, table item 10 - NCUTCD recommends a minimum roadway size

for the R5-6 sign of 18\" x 18\", not 24\" x 24\". The League supports

NCUTCD\'s recommendation. This size would still provide very good symbol

legibility, and would bring the R5-6 in line with the minimum sizes

called for other Selective Exclusion signs in the MUTCD. Note that a

comparable change will also need to be made to Table 2B-1.

6\. Sheet 1, table item 31 - NCUTCD recommends deleting the minimum

roadway size for the R5-4a sign, since this sign will not be used on 0D

roadways. The League supports NCUTCD\'s recommendation.

7\. Sheet 1, table item 37 - Replace the term \"Advance Grade Crossing\"

with \"Highway-Rail Grade Crossing Advance Warning\" to be consistent

with the description of the W10-1 sign in Chapter 8B.

8\. Sheet 1, table item 37 - NCUTCD recommends a minimum shared-use path

size for the W10-1 sign of 18\" diameter, not 30\". The League supports

NCUTCD\'s recommendation. The 30\" size is inappropriate (far too large)

for shared-use paths, and is much larger than the 18\" standard warning

sign size used throughout Chapter 9B. An 18\" size will bring this sign

in conformance with the size proposed in Part 8 for shared-use path /

rail crossings, and will provide good legibility at a size appropriate

for a pathway environment.

9\. Sheet 2, table item 11 - Insert a 18\" x 9\" minimum size for the

W16-2aP AHEAD plaque for shared-use paths, as this plaque may be useful

on shared-use paths, and the 18\" x 9\" size would be appropriate for
use

with typical warning signs on paths.

10\. Sheet 2, table item 32 - Replace the term \"Bicycle Route\" with

\"Numbered Bicycle Route\" to be consistent with the intended
application

of the M1-8 and M1-8a, and to reduce confusion with other non-numbered

bicycle route signs.

11\. Sheet 2, table item 32 - NCUTCD recommends a minimum roadway size

for the M1-8 and M1-8a sign of 18\" x 24\". The League supports
NCUTCD\'s

recommendation. This will improve legibility on roadways, and bring the

M1-8 and M1-8a into conformance with the minimum roadway size

recommendations for the M1-9 sign.

12\. Sheet 2, table item 33 - NCUTCD recommends a minimum shared-use

path size for the M1-9 sign of 12\" x 18\". The League supports
NCUTCD\'s

recommendation. This will provide good legibility on paths, and bring

the M1-9 into conformance with the minimum path size recommendations

for the M1-8 and M1-8a signs.

Figure 9B-2 - Regulatory Signs and Plaques for Bicycle Facilities:

1\. The R5-6 sign should be depicted at the same size (18\" x 18\") as

other Selective Exclusion signs (R9-3, R9-13, R9-14) (see comment

above).

Figure 9B-3 - Warning Signs and Plaques for Bicycle Facilities:

1\. In human factors testing commissioned by NCUTCD, the selected W11-15

sign symbol design depicted in the proposed MUTCD tested poorly as

compared to other alternative sign designs. Implementing the proposed

design as the standard sign for this application will likely result in

poor comprehension and legibility. LAB supports the revised

NCUTCD-recommended design for the W11-15.

Figure 9C-9 - Shared Lane Marking

LAB definitely endorses the content of this figure as proposed by FHWA.

Part 10 -

No comments.