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NACTO Recommendations for Updates to FHWA Design Guidance

December 2020

The following is a living document that will be updated as city needs and FHWA proposals evolve. 

The Federal Highway Administration (FHWA) has broad rulemaking power that guides and impacts the majority of major streets in the United States. In particular, FHWA oversees:

  • Manual on Uniform Traffic Control Devices (MUTCD) – the MUTCD sets highly detailed standards for traffic signals, signs, and road markings on all public roads.  The MUTCD, along with ADA regulations, is one of the few Federal design standards that applies to all public roads.
  • National Highway System (NHS) design standards – Under the FAST Act and previous highway legislation in 23 CFR 625, FHWA is responsible for designating NHS standards, which affects Interstates and thousands of miles of urban streets. These standards include AASHTO Policy on Geometric Design of Highways and Streets (the Green Book) and FHWA’s Controlling Criteria. Currently, the NHS design standards include detailed highway design requirements such as clear zones and lane width for high-speed roads, but does not provide a similar ‘floor’ for pedestrian or bicycle safety. The FAST Act specifically directs USDOT to consider the NACTO Urban Street Design Guide in these standards.

Both the NHS design standards and the MUTCD are living documents that require periodic updates to reflect new research on road safety and adapt standards to changing land-uses and development and travel patterns. Both are overdue for an update.

For example, in response to research showing the adverse safety and economic effects of NHS design standards in urbanized areas, FHWA, in a 2015 rulemaking, eliminated most of these ‘controlling criteria’ except for roads designed for 50 mph or higher speeds. However, more remains to be done as the demonstrably unsafe old standard designs are still allowed without requiring a design exception, even in new construction, and most states still use the older standards.

Similarly, the MUTCD was last fully updated in a 2009 rulemaking, with smaller updates in 2012. FHWA has indicated that an MUTCD update is forthcoming and it is expected to improve speed limit guidance and several other areas, but not to address the structure or process issues with the document that lead to lengthy delays between essential updates.

Through NACTO, city transportation practitioners are committed participants in the national design dialogue, including adding city voices as a sponsoring organization of the National Committee on Uniform Traffic Control Devices. Sustained involvement by cities is key to achieving a reduction in traffic deaths and serious injuries while improving access and goods movement in the United States. The following catalogues the recommendations of city transportation experts and practitioners to update and improve FHWA-controlled design guidance for local streets and roadways.


Requested Updates to the Manual on Uniform Traffic Control Devices (MUTCD)

1. Ensure that city transportation practitioners are actively involved in MUTCD updates. As the nation’s primary roadway mileage and traffic signal owners and maintainers, cities should be recognized as primary users of the MUTCD, and given a voice commensurate with that knowledge.

a. FHWA should take the lead on MUTCD revision discussions, holding frequent, virtual meetings to develop and review MUTCD content along with invited stakeholders including cities, professional organizations, and other roadway owners such as states and counties.

b. FHWA should create open lines of communications between NACTO and FHWA’s Office of Infrastructure and Office of Operations, particularly the MUTCD team, through periodic meetings/calls – at first quarterly, then biannually.

2. Reform the MUTCD’s structure to make frequent or partial updates more practical and expedient. FHWA can split the core standards of the MUTCD into a minimally prescriptive standards rule describing traffic control devices such as signals and signs, and a separate guidance document that would be more readily updated, or shift MUTCD revisions out of the rulemaking process by adopting them via reference, as is done with other national standards.

a. Dramatically simplify the MUTCD regulation and make its update process fully transparent, as befits a major industry-wide document, by moving most content of the MUTCD into a set of guidelines that can be updated in a transparent and ongoing process, then adopted as a rule by reference.

i. The MUTCD can be published in a user-friendly document that includes both guidance and rules, but whose non-rule portions can be updated more frequently based on open professional discussion.

b. Transition away from signal warrants to a prioritization process focused on non-motorized safety and access rather than requiring high numbers of pedestrians before installing a signal.

3. Update critical areas in the upcoming MUTCD revision, in particular:

a. Speed limits. Following recommendations from NTSB and other safety experts, FHWA should update the 2012 Methods and Practices for Setting Speed Limits report, to develop proactive guidelines for speed limit setting, or adopt the speed limit setting methodology outlined in NACTO’s City Limits: Setting Safe Speed Limits on Urban Streets. FHWA has indicated that it will make the modifications necessary to reduce reliance on the 85th percentile operating speed in speed-limit-setting guidance, as the NCUTCD has already approved, and should ensure that new regulations and guidance achieve the goal of injury minimization.

b. Issue an active transportation network signal warrant that makes people walking and biking equal to motor vehicle users as a basis for signalization.

c. Signal warrants: Rationalize pedestrian signal options by revising the pedestrian signal warrant to match the easier-to-meet Hybrid Beacon warrant, and eliminating language that discourages the use of Hybrid Beacons at intersections.

d. Pedestrian Signals: Institute a requirement (“shall” clause) to install pedestrian signals when signals are built or upgraded; pedestrian signals are currently optional despite their necessity for creating an accessible and safe roadway, with very rare exceptions.

e. Bicycle signals: Provide flexibility in using bicycle signals and markings, which are currently subject to much stricter requirements than comparable pedestrian and vehicular signals; remove the prohibition on using green bicycle signals during times when turning vehicles may proceed after yielding to bikes, and remove the prohibition on continuing a marked bicycle lane at an intersection adjacent to a turn lane. Allow near-side 4” bicycle signals as a primary signal.

f. Clarify that non-traffic-control color and art are permitted in the roadway, and that colors and art may be used inside other traffic control markings so long as the function of the markings remains. If necessary, restrict this permission to under-50 mph roads.

g. Instruct states to expeditiously remove similar obstacles in their MUTCDs through design exceptions or other early action similar to FHWA interim approvals, even before rulemaking can begin.

h. Update Signage in keeping with NCUTCD Recommendations. In particular:

i. Allow in-road Yield/Stop for Bicycle and pedestrian signs using the bicycle symbol.

ii. Allow the Turning Vehicle Yield to Bicycle and Pedestrian Sign.

4. Provide a streamlined experimentation process to allow more responsive, better- informed changes to the MUTCD in the future. 

a. Allow roadway owners/jurisdictions to add themselves to an existing experiment, avoiding the need to file a separate experiment.

b. Develop or approve a short, practical guide to experimentation setting forth FHWA’s expectations about types of data to be collected, and what the criteria will be for declaring the experiment successful.

c. Develop or approve a simple experimental data collection template or checklist that roadway owners can include in grant applications, contracts, and work orders and modify as needed.

d. Issue a clarification letter or Interim Approval, as appropriate, permitting and describing a second stage of testing for new traffic control devices. The rules surrounding this second stage of testing should be easy to use, with simple reporting criteria using data types readily available at most sites. This might be done through the existing Interim Approval process, since that process already requires notification to FHWA.

e. Work to align NCHRP studies and UTC research to meet requests for experimentation requirements, rather than requiring cities to entirely self-fund this research.


Requested Updates to the National Highway System’s (NHS) Standards & Other Rules

1. Allow cities to use locally adopted design standards on all city-owned streets in the NHS. This may be done by either:

a. Relieving states of their duty to separately conduct design review of FHWA-funded projects on city-owned roads that have already received local approval, or by

b. Requiring that states defer to locally-adopted design standards in reviewing projects on all city-owned streets.

2. Require states to consider locally adopted design standards when constructing or reconstructing roadways in jurisdictions with such standards on the NHS.

3. Adopt a rule to standardize the inclusion of dedicated accessible pedestrian facilities, such as sidewalks, and all-ages bicycle facilities on the NHS, requiring a design exception to construct or reconstruct a roadway without these features. This should apply to all Federal-aid highway projects, pursuant to the existing legal requirement to not adversely impact the safety of non-motorized traffic in a Federally funded project. FHWA’s existing guidance on all-ages bicycle facilities and NACTO’s guidance on the same are acceptable bases for bicycle facility selection.

a. Through MPOs, require states to file a ten-year plan to provide sidewalks and all-ages bicycle facilities on all NHS arterials and collectors in urbanized areas.

b. Establish research-driven national design standards for multi-lane surface roads and urbanized-area roads with speed limits of 35 mph or above that includes maximum acceptable distance between safe crossing points, and a standard of care for pedestrian crossings.


NACTO State & Federal Policy Program >>