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### July 28, 2008

### 

### U.S. Department of Transportation

Dockets Management Facility

1200 New Jersey Avenue, SE

Washington, D.C. 20590

RE: **Notice of Proposed Amendments to the Manual on Uniform Traffic
Control Devices**

> *Chapter 2G. Specific Service Signs, page 765 lines 42-51 and page 766
> line 1 on the use of Dual Logo Sign Panels*

On behalf of Interstate Logos and its' subsidiaries, who currently
operate or manage logo signing programs for nineteen (19) state
Transportation Departments across the United States, I would like to
take this opportunity to offer formal comments on the Notice of Proposed
Amendments (NPA) to the Manual on Uniform Traffic Control Devices
(MUTCD), specifically Chapter 2G. Specific Service Signs, page 765 lines
42-51 and page 766 line 1 on the use of Dual Logo Sign Panels.
***[Interstate Logos and its' subsidiaries are opposed to the inclusion
of this language due to lack of adequate field research at this time,
potential motorist confusion related to categorical placement, and
issues of motorist comprehension and information
overload]{.underline}**.*

The research sited for the inclusion of language allowing dual logo sign
panels was a study submitted on August 1, 2004, by the Texas
Transportation Institute (TTI) on the "Effects of Adding Dual Logo
Panels to Specific Service Signs". The study involved a laboratory test
utilizing a slide presentation on a laptop computer to provide sample
images of specific service signs to the participants containing some
images with up to two (2) dual logos on a single specific service sign.
Although the TTI study references a field experiment and evaluation that
was to be conducted by the Kentucky Transportation Cabinet that would
provide additional guidance related to this issue, no such study was
ever completed. ***[To our knowledge, no field research was or has been
conducted to substantiate the TTI findings]{.underline}***.

In fact, the TTI study recommendations stated, "Because the research
evaluation did not include a field evaluation, the initial
implementation efforts should be closely monitored for potential adverse
operational or safety impacts." ***[Considering the potential impact
highlighted by this statement, should the Manual be modified based on
this laboratory research alone?]{.underline}***

In February 2007, Kimley-Horn & Associates, Inc. prepared a "Specific
Service Sign Comprehensive Study" for the Federal Highway
Administration. Although this was two (2) years after the TTI study, the
"Research Recommendations" of the Kimley-Horn study included:

> "Research should be conducted and Standards should be developed
> indicating under what circumstances it is permissible to use a logo
> panel with two business logos on it. This would most likely occur at a
> combined gas station and restaurant facility. Items
>
> that should be addressed in the Standards include: when dual logos can
> be used, the size of the logo for each business, how many dual logo
> panels can be placed on a single sign, and which Specific Service sign
> the logo should be placed on. This recommendation was also a
> recommendation of the \[NCUTCD\] G/MI task force."

***[The language of the NPA ignores this recommendation by including the
language authorizing the use of dual logos without additional
research.]{.underline}***

The Kimley-Horn study also stated, "A study should be performed to
determine exactly how much information on a Specific Service sign is too
much information for a driver to comprehend." ***[The language in the
NPA has created a twelve (12) panel logo sign, actually decreasing the
size of the messages to be comprehended by the motorists, without actual
field research assessing the positive and negative impacts or potential
safety implications.]{.underline}***

Since the sole research sited in the Federal Register for inclusion of
language in the NPA related to dual logos is the August 2004 TTI study,
it is important to revisit the way this study was developed, data
collected, and the conclusions of the study. The recommendations of the
TTI study included the following (verbatim):

-   The research results did not indicate a need to prohibit the use of
    dual logo panels.

-   Because the research evaluation did not include a field evaluation,
    any initial implementation efforts should be closely monitored for
    potential adverse operational or safety impacts.

-   Dual logo panels may be implemented on Specific Service signs with
    qualifications.

-   To minimize the potential for information overload and to maximize
    the legibility of Specific Service signs, dual logos should be
    utilized on a Specific Service sign only when all available logo
    panels are already in use and there is no room for additional logos.

-   The research did not evaluate the maximum number of dual logo panels
    that should be presented on a single Specific Service sign. The
    signs evaluated as part of the experimentation contained two dual
    logo panels and the researchers recommend that this be the maximum
    number of dual panels permitted. Additional evaluations may be
    necessary to determine whether more than two dual logos should be
    permitted on a single sign.

-   The research found that mixing food and gas logos in a dual logo
    panel did not significantly impact the effectiveness of the dual
    logo.

As is outlined in the third and fifth bullet above, the TTI study
recommended limitations be placed on implementation including limiting
the number of dual logo panels to two (2) per sign. In fact, as is
stated in the recommendations, TTI did not include any examples in their
study that had more than two (2) dual logos on a sign. ***[The language
in the NPA limits dual logos to containing only GAS or FOOD service
business logos, but does not restrict the number of dual logos that can
be displayed on a sign beyond a "should" condition of no more than two
(2), thus allowing up to six (6) dual logos per sign or twelve (12)
total messages per sign.]{.underline}*** Once again, this is contrary to
the findings in both the TTI study and the Kimley-Horn study which
states before arbitrarily increasing the number of messages that can be
displayed, "A study should be performed to determine exactly how much
information on a Specific Service sign is too much information for a
driver to comprehend."

The fourth bullet of the TTI study recommendations indicates that dual
logos should only be used, "when all available logo panels are already
in use and there is no room for additional logos." ***[The language in
the NPA makes this recommendation a "should" condition, thus allowing
for the use of dual logos even if space is available for the display of
a single business logos.]{.underline}***

The TTI study outlines the very concerns which we still have about the
use of dual logo sign panels:

-   Categorical Placement,

-   Recognition/Legibility, and

-   Information Overload.

[Categorical Placement]{.underline}

***[It is our belief that a dual logo should not display businesses
providing different services for the motorist, for example a
"Shell/McDonald's" dual logo should not be allowed]{.underline}***.
Specific Service Signs include a legend, either "GAS, FOOD, LODGING,
CAMPING, ATTRACTIONS, or 24-HOUR PHARMACY" to inform motorists of the
service provided by the individual businesses whose logos are displayed
on the sign. One could argue that this legend assists with the motorist
comprehension of the actual business logos by providing initial clues
for recognition of the logo panels contained on the sign. In essence, by
reading or recognizing the legend, the motorist would more quickly
recognize the business logos that are normally found or associated with
that service legend. ***[The use of dual logos, specifically to display
the logo of a service other than the one shown on the legend, provides a
"false" message to the motorist, and negates the very purpose for the
legend, causing added confusion for the motorists]{.underline}***. While
the inclusion of a "McDonald's" logo on the same logo panel as a "Shell"
logo may not cause added confusion related to the service category, a
dual logo displaying "Shell" and a not so recognizable or a single
location restaurant potentially would cause confusion, such as "Joey
D's," "Jack's," or "Angie's," which are all FOOD businesses currently
participating in the Georgia Logo Signing Program. ***[Additionally, the
language in the NPA does not limit a business location from displaying
the same duel logo on both the GAS and FOOD logo signs.]{.underline}***

[Recognition/Legibility]{.underline}

As was pointed out earlier, the TTI study was conducted utilizing a
slide presentation on a laptop computer to provide sample images of
specific service signs to the participants containing some images with
up to two (2) dual logos on a single specific service sign. Laboratory
research does not take into account the other distraction factors of
actually operating a motor vehicle along the roadway, including
awareness of other vehicles, traffic control devices, regulatory and
warning signage, weather conditions, and other guide and motorist
information signs, not to mention, radios, cell phones, and GPS devices
in the vehicle.

The results of the survey did indicate a significant difference in the
recognition level between familiar and unfamiliar logos, even at the
highest exposure time, stating, "The ability to recognize a logo is more
dependent on driver familiarity with the logo than whether the business
is located in a dual or single panel." Since no standards are
established for a businesses logo design that is translated on a
business logo panel, the TTI study accurately concluded in its final
sentence, "The lack of logo panel design criteria make it difficult to
restrict the use of dual logos based on performance criteria." In this
final statement, the TTI study is highlighting a primary concern related
to dual logos: ***[It is simply not possible to limit the use of dual
logos to businesses whose logos are easily recognizable such as "Shell"
or "McDonald's", so the potential for having dual logos that are
confusing or incomprehensible exists which could lead to safety
issues.]{.underline}***

[Information Overload]{.underline}

As was stated in the "Specific Service Sign Comprehensive Study"
prepared for the Federal Highway Administration by Kimley-Horn &
Associates, Inc., "Motorist information overload is a concern because
drivers might behave in an unsafe and erratic manner and might slow down
to give themselves more time to process the information." The
Kimley-Horn study correctly points out that no research specific to the
number of messages that is comprehendible on a logo sign have been
conducted, and such a study should be conducted before increasing or
decreasing the number of logos per sign from six (6). ***[Once again,
the language of the NPA does not restrict the number of dual logos that
can be displayed on a sign beyond a "should" condition of no more than
two (2), thus allowing up to six (6) dual logos per sign or twelve (12)
total messages per sign.]{.underline}***

Given the concern about the aging driver, comprehension issues, and
potential information overload, without adequate field research the
language included in this section of the NPA seems contrary to the
policies in place for edits or additions to the Manual and the goals
established for ensuring the motorist safe and efficient travel. The use
of dual logos actually decreases the size of the message the motorist
must comprehend while increasing the number of messages the motorist
must comprehend, which both seem to be contrary to the other proposed
changes related to roadway signage. ***[Interstate Logos and its'
subsidiaries urge FHWA consider removing page 765, lines 42-51 and page
766 line 1 from the NPA until adequate field research has been completed
to substantiate the need and implications of this significant
change.]{.underline}***

Thank you for allowing us the opportunity to provide these comments. If
you have any questions or need additional information, please do not
hesitate to contact me.

Respectfully submitted,

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Everett Stewart

President

estewart@interstatelogos.com

\(800\) 468-7805

Interstate Logos was formed in June of 1988 and is currently responsible
for the operation of nineteen (19) logo signing companies in the United
States, ten (10) Tourist Oriented Directional Signing (TODS) operations,
and a logo signing and TODS company in the Province of Ontario.

cc: Hari Kalla, FHWA

William R. Lambert, Chairman, NCUTCD GMI Technical Committee

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