Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 As requested, the draft VSP has been reviewed and we submit the following comments: 1. First, it’s obvious that a lot of work has gone into this project, and we appreciate the effort of all of those involved. This is a very interesting and thorough document. Thank you. 2. On page 7, Chapter 2, item 1a, line 16: Recommend adding “rumble strips” after “speed humps.” 3. On page 8, Chapter 2 item 7d, line 43: Recommend revising “road user groups?” to “road users.” 4. On page 8, Chapter 2, item 7e, line 44: Recommend removing “public,” since private property is now involved. 5. On page 10, Chapter 2, item 19, line 32: Basically, all road users need to be addressed by traffic control devices. 6. On page 10, Chapter 2, item 20, line 34: We shouldn’t expect small agencies and private property owners to acquire traffic engineering expertise. However, the fundamental in the Manuals should be clear enough to make the basic standards/rules easily understood. At least in Ohio, the Ohio DOT District and Central Office personnel and County Engineers are also available to provide assistance in understanding the Manual provisions. 7. On page 11, Chapter 2, item 22, line 13: Could add “and is referenced in most state motor vehicle laws.” Ohio Revised Code 4511.09 requires a state manual in conformance to the national one. 8. On page 12, Chapter 2, item 29, lines 14 and 32: For consistency, revise “right of way” to “right-ofway.” 9. On page 13, Chapter 2, item 32a, line 23: We’re not familiar with the term “long zone”; however, we do have a provision in Section 3B.02 of the OMUTCD that extends no-passing zones beyond what is shown in the MUTCD. The distance between successive no-passing zones should be no less than 400 feet for speeds less than 50 mph and no less than 600 feet for speeds 50 mph or greater. When the distances are less than these, the single or double no-passing lines should be extended to connect the zones. 10. On page 13, Chapter 2, item 32b: ODOT currently publishes a separate Ohio MUTCD, and there are a number of differences in the two Manual that could be considered significant, especially in the signing area. The following highlight the more significant differences: a. The OMUTCD references the ODOT Sign Designs and Markings Manual (SDMM) instead of FHWA’s Standard Highway Signs and Marking book. The SDMM includes some signs that are not addressed in the FHWA’s book, but more significantly, the OMUTCD uses a Freeway and Expressway Guide Sign Design Method that is based on a “Sign Level system.” This is described in Appendix C of the SDMM. Basically, as noted in OMUTCD Section 2E.01, Paragraph 2, “types of signs are assigned different levels (i.e., 0, 1, 2, 3 and 4). For example, an overhead Pull-Thru Sign is a level 1 sign and a mainline Supplemental Guide Sign is level 2. The level assignment is used to determine the size of elements used in the design of the sign (see Tables 2E-2 and 2E-3). The design method described in Appendix C of the SDMM also applies to entrance ramp approach signs on roads intersecting freeways and expressways.” b. Since it doesn’t reflect the ORC, the OMUTCD does not include the KEEP RIGHT EXCEPT TO PASS sign. We continue to use the SLOWER TRAFFIC KEEP RIGHT sign. We also use a THROUGH TRAFFIC KEEP RIGHT/LEFT sign (OMUTCD Section 2B.32). c. In OMUTCD Section 2B.53, the Standard requires that “when a flashing yellow arrow indication is used a LEFT TURN YIELD ON FLASHING YELLOW ARROW (R10-H12c) sign shall be used with it for at least five years.” d. Instead of the R12-5 Weight Limit sign from the MUTCD, the OMUTCD uses an Ohio version of the R12-H5 sign for truck weight limits, which uses four truck symbols. 1 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 e. Since all state highways in Ohio have been designated as part of the National Network, the special truck routing National Network signs addressed in Section 2B.63 of the MUTCD are not used in Ohio. f. OMUTCD Section 2C.08 includes an additional Standard paragraph requiring that: “The speed shown on the advisory speed plaque shall be equal to or less than the posted or statutory speed limit. Where the advisory speed is determined to be higher than the posted or statutory speed limit, the advisory speed plaque shall not be used.” g. OMUTCD Sections 2C.21 and 3B.01 provide Guidance that “center line markings should not be applied within 150 feet of a one-lane bridge.” h. In addition to the NO CENTER LINE sign, OMUTCD Section 2C.34 addresses the use of a NO EDGE LINE sign. i. For Route Signs, the OMUTCD: i. does not use the MUTCD text allowing the name of the State on the blue background of the Off-Interstate Business Route sign; ii. addresses the Ohio State Route sign, rather than the generic one in the MUTCD; and iii. provides an Alternate County Route sign and a Township Route sign. j. OMUTCD Section 2D.42, includes the following provision as Paragraph 4: “If used in rural areas, Distance signs should be placed approximately 300 feet beyond intersections of numbered routes and a minimum of 200 feet beyond confirming Route Assemblies.” k. In OMUTCD Section 2E.10 the following additional Guidance and Option are provided: “The legend sequence from top to bottom should be route shield information, street name(s), and the destination name(s). This sequence should remain the same even when one or more of these components is not included. When appropriate, cardinal direction information should be included either above or beside the shield(s). Regardless of the number of route shields used, and the presence or absence of cardinal direction information, the route shield component of the sign is considered as one line. Option: Additional destination names may be included on a Supplemental Guide sign.” l. In OMUTCD Section 2E.21, when discussing the new Overhead Arrow-per-Lane provisions, “conditions allow” from the MUTCD was revised to “there is an operational need”: Guidance: Overhead Arrow-per-Lane guide signs should be located at approximately 1/2 mile and 1 mile in advance of the exit or split, and at approximately 2 miles in advance of the exit or split where space is available and there is an operational need. m. In Section 2E.23, Paragraph 2, the OMUTCD defines a conventional exit as “(a single lane exit without an option lane).” n. OMUTCD Section 2E.23 includes the MUTCD language in Paragraph 6 that “Advance Guide signs that are mounted overhead shall not display a down arrow over an option lane.” However, given existing geometrics this is a problem in Ohio, and the ODOT Traffic Engineering Manual (TEM) contains information about signing techniques used to address optional lanes. At some interchanges, it may be necessary to continue to use the current designs, or a combination. 2 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 o. OMUTCD Section 2E.24 includes the following Guidance: “On the yellow portion of the Advance Guide and Exit Direction signs, the black border should extend to the edge of the signs to provide continuity with the white border on the green portion of the signs.” p. For uniformity, the OMUTCD provides additional guidance on expressway at-grade intersection guide signing in OMUTCD Section 2E.29 and the ODOT Traffic Engineering Manual (TEM) in this area (green Arial font below is the OMUTCD text; black is from the MUTCD; paragraph nos. and other formatting have been removed). Section 2E.29 Signs for Intersections at Grade Guidance: Except as noted in Subsections 2E.29.1, if there are intersections at grade within the limits of an expressway, guide sign types provided in Chapter 2D should be used. However, such signs should be of a size compatible with the size of other signing on the expressway. Option: Advance Guide signs for intersections at grade may take the form of diagrammatic layouts depicting the geometrics of the intersection along with essential directional information. Support: Additional information about this type of signing on ODOT-maintained highways is provided in Part 2 of ODOT’s “Traffic Engineering Manual” (see Section 1A.11). Section 2E.29.1 Expressway Street Name Sign (D3-H3 or D3-H3a) Support: Expressway Street Name (D3-H3 or D3-H3a) signs identify expressway at-grade intersections. Guidance: An Expressway Street Name sign should be installed in urban areas at all important expressway at-grade intersections regardless of other route signs that might be present, and should be installed in rural areas to identify important routes that are not otherwise signed. Option: For added guidance, an additional Expressway Street Name (D3-H3 or D3-H3a) sign may be installed in advance of the intersection. If used, this additional sign may be placed approximately 500 feet in advance of the intersection. The Street Name (D3-1) sign (see Section 2D.43) may be used as an alternative to the D3H3 or D3-H3a sign at intersections where, for example, the larger sign might adversely affect cross-corner sight distance. Section 2E.29.2 Expressway At-Grade Intersection Advance Street Name Sign (D3-H4) Support: Expressway At-Grade Intersection Advance Street Name (D3-H4) signs identify an upcoming expressway at-grade intersection. Guidance: An Advance Street Name (D3-H4) sign should be installed in advance of all important expressway intersections not otherwise signed. The sign should be placed approximately 1/2 mile, or other suitable distance based on engineering judgment, in advance of the intersection. Standard: Advance Street Name signs, if used, shall supplement rather than be used instead of the Street Name signs at the intersection. 3 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 q. The MUTCD text alone also doesn’t seem to adequately address guide signing on freeway/expressway off-ramps. However, in this case, rather than add information in the OMUTCD to address this, usage notes have been provided on some sign designs in the Ohio SDMM to indicate what size guide signs to use on off-ramps. r. In Section 2E.33, the OMUTCD adds the following in Paragraph 2 (green Arial font below is the OMUTCD text; black is from the MUTCD): Guidance: For major and intermediate interchanges (see Section 2E.32), Advance Guide signs should be placed at 1/2 mile and at 1 mile in advance of the exit with a third Advance Guide sign placed at 2 miles in advance of the exit if spacing permits and engineering judgment indicates that there is an operational need. At minor interchanges, only one Advance Guide sign should be used. If the sign is located less than 1/2 mile from the exit, the distance displayed should be to the nearest 1/4 mile. Fractions of a mile, rather than decimals, should be displayed in all cases. s. In Section 2E.37, the OMUTCD provides (green Arial text is Ohio-only): Guidance: Except as noted in Paragraph 10, the E5-H1c should not be used in gore areas where an E5H1a sign could be installed with sufficient lateral offset. Option: The Narrow Exit Gore (E5-H1c) sign may be used where engineering judgment predicts a high occurrence of gore sign impacts. t. In Section 2H.06, the OMUTCD adds information about a Ramp Enhanced Reference Location sign (D10-H5a), which indicates the names of the routes being connected. u. The 24-Pharmacy signs are not used in Ohio. v. Logo Sign Panels in the OMUTCD are 48x36 and 24x18 instead of the 60x36 and 30x18 sizes shown in the MUTCD. Although the sizes are different, they are considered to be within the parameters set by the MUTCD. Also, in Section 2J.07, the OMUTCD allows for two lines of legend instead of just one. w. The Logo program in Ohio does not use the signs at intersections. x. OMUTCD Section 2K.01 provides that a facility shall be eligible for TODS only if it derives “its major portion of income or visitors during the normal business season from road users not residing within 10 miles of the facility and attendance at which is no less than 2,000 in any consecutive twelve month period.” y. OMUTCD Section 2K.01 also provides that (green Arial text is Ohio-only): Standard: When used, tourist-oriented directional signs shall be used only at intersections on rural conventional roads and expressways. They shall not be used at intersections on conventional roads or expressways in urban areas or at interchanges on freeways or expressways. They shall not be used on conventional roads to direct traffic onto a freeway ramp. z. In Section 2K.04, the OMUTCD provides that (green Arial text is Ohio-only): Standard: 4 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 The size of a tourist-oriented directional sign shall be limited to a maximum height of 6 feet. Additional height shall be allowed to accommodate the addition of the TOURIST ACTIVITIES message provided in Section 2K.02 and the action messages provided in Section 2K.05. The number of intersection approach signs (one sign for tourist-oriented destinations to the left, one for destinations to the right, and one for destinations straight ahead) installed at an intersection shall not exceed three. The left and right assemblies shall be located on the approach to the intersection, and the straight-through assembly on the far side of the intersection. The number of sign panels installed on each sign shall not exceed four. Guidance: The sign panels for right-turn, left-turn, and straight-through destinations should be on separate signs. The left-turn destination sign should be located farthest from the intersection, then the right-turn destination sign, with the straight-through destination sign located closest to the intersection (see Figure 2K-2). Standard: Signs for facilities in the straight-through direction shall be considered only when there are signs for similar destinations in either the left or right direction. aa. Also, in Section 2K.04, Paragraph 9 (green Arial text is Ohio-only): Standard: All directional sign panels and other parts of the sign shall be the same width, which shall not exceed 6 feet. bb. In Section 2K.06, the OMUTCD shows the “shoulds” in Paragraphs 1 and 2 of the MUTCD as “shalls.” cc. In Section 2M.09, the OMUTCD shows the brown background as the first choice, and green as the second choice in order of preference for the background color for recreational and cultural interest area guide signs. dd. Some sign sizes have been revised slightly in the OMUTCD from what is shown in the MUTCD. The primary reason is for efficiencies in sign fabrication. For instance, flatsheet aluminum is readily available in widths up to 48 inches. Making a 52 or 54 inch sign is much more difficult, as the splicing of flatsheet aluminum is required, or else extrusheet can be used. Some signs can be reduced to 48 inches without unduly compromising sign effectiveness. For larger signs, some signs have been revised in increments of even feet in width and height, again for efficiency in sign fabrication. ee. In Section 3B.02, the following additional text is provided in the OMUTCD (green Arial text is Ohio-only): There is explicitly no requirement under this Manual that no-passing zones shall be marked at intersections, notwithstanding the provisions of any other section of this Manual. Option: No-passing zones may be marked at rural and urban intersections when engineering judgment so dictates. And Guidance: 5 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 The decision as to whether or not a no-passing zone should be marked at intersections is a matter of engineering judgment. When used, the no-passing zone should start at least 100 feet in advance of the intersection. The no-passing zone marking should not be less than 500 feet in length, except in advance of an intersection, or as a result of a special engineering study. If the actual no-passing zone distance is less than 500 feet, an additional length of marking should be added at the beginning of the zone. The distance between successive no-passing zones should be no less than 400 feet for speeds less than 50 mph and no less than 600 feet for speeds 50 mph or greater. When the distances are less than these, the single or double no-passing lines should be extended to connect the zones. No-passing markings should be used on approaches to other locations where passing should be prohibited. Standard: In locations where there are dips or undulations in the profile of the pavement which create areas where the actual pavement surface is more than 3.5 feet below the line of sight, the no-passing line shall be extended as required. ff. In Section 3B.19 of the OMUTCD, the following has also been added (green Arial text is Ohioonly): Standard: Parking space markings shall be white and not less than 4 inches, nor more than 6 inches wide. Guidance: Where angle parking is permitted under Section 4511.69 of the Ohio Revised Code (see Appendix B2), the stalls should be marked with a series of solid lines spaced not less than 8.5 feet apart and placed at the desired angle. gg. OMUTCD Section 4B.06 addresses traffic signals on state highway extensions in villages and the process established for approval of them, per ORC 4511.11(C). hh. In Section 4D.05, the following Option was added (green Arial text is Ohio-only): If U-turns are permitted from an approach and a steady circular red signal indication is simultaneously being displayed to road users making a right turn from the conflicting approach to the left, road users making a right turn on red may be advised of the operation by the installation near the right-turn signal face of a NO TURN ON RED (R10-11b), a RIGHT TURN ON RED MUST YIELD TO U-TURN (R10-30) or a NO TURN ON RED blank-out sign active during the U-Turn phase (see Section 2B.54). ii. Also, a decision was made to use the flashing red arrow provision only in very limited circumstances, basically, just when a part-time signal goes on flasher. Much of the MUTCD language about flashing red arrows was not used in the OMUTCD. jj. In Section 4D.18, the following was added to the OMUTCD due to concerns about introduction of the flashing yellow arrow (green Arial text is Ohio-only): Support: Research and field experience with the flashing left-turn YELLOW ARROW signal indication has found that most road users recognize the meaning of this application. However, it has also been noted that an educational campaign in advance of installation, and supplemental signing during implementation aids in comprehension. Guidance: A public information campaign should be used in advance of projects introducing this device in an area to make road users aware of the planned introduction of the new signal display type and its meaning.. Once the flashing left-turn YELLOW ARROW signal indication has been in use within an area for a while, public information campaigns should not be needed. 6 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 For consistency, when installing a flashing left-turn YELLOW ARROW signal indication for protected/permitted operation at a new location, the same treatment should be considered for nearby signal installations with a similar operation. Standard: The LEFT TURN YIELD ON FLASHING YELLOW ARROW (R10-H12c) sign (see Figure 4D-7) shall be used with the installation of each flashing left-turn YELLOW ARROW signal indication within a jurisdiction for at least five years. kk. In Section 4D.20, the following Standard was also added (green Arial text is Ohio-only): Standard: The LEFT TURN YIELD ON FLASHING YELLOW ARROW (R-10-H12c) sign (see Figure 4D-12) shall be used with the installation of each flashing left-turn YELLOW ARROW signal indication within a jurisdiction for at least five years (see Section 4D.18). ll. In Section 4D.30, the following was added (green Arial text is Ohio-only): If a traffic control signal with left-turn signal face is operated in flashing mode during off-peak hours, the supplementary sign LEFT TURN YIELD ON FLASHING RED ARROW AFTER STOP (R10-27) (see Figure 2B-27) should be used. mm. In OMUTCD Figure 4E-2, two of the five scenarios shown in the MUTCD were deleted: nn. In Part 6, the OMUTCD has a number of differences in the text and figures based on the fact that we have taken the position that a shifting tapers should be approximately L in length, except that for speeds under 50 mph it may be approximately 1/2L. oo. In Section 6D.01, Paragraph 27 the OMUTCD revised “Portable concrete barriers” from the MUTCD to “temporary traffic barriers.” pp. In Section 6E.03, the OMUTCD provides the following additional Guidance (green Arial text is Ohio-only): The STOP/SLOW paddle should be the primary and preferred hand-signaling device because the STOP/SLOW paddle gives road users more positive guidance than red flags. Use of flags 7 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 should be limited to emergency situations and low-speed and/or low-volume locations which can best be controlled by a single flagger. qq. Due to accident experience with vehicles coming from behind a barricade placed in the roadway, and not being seen until the last minute by approaching drivers, in the Figure and Notes for Figure 6H-8 (Road Closure with an Off-Site Detour), the recommended placement of the detour barricades is at the edge of the traveled way. Note 3 in the OMUTCD is: “If the road is closed a short distance beyond the intersection and there are few origin/destination points beyond (for example, a few residences), the Type 3 Barricade shown in the figure may be moved to the center of the traveled lanes.” And a new Note 4 has been added: “If the barricades are located as in Item 3 above, the ROAD CLOSED and DETOUR signs shall be placed only on the barricade centered in the lane of travel of traffic approaching the closure. The barricade centered in the lane of travel of departing traffic shall not be signed. The barricades in adjacent lanes shall be offset longitudinally from each other an adequate distance in order to permit traffic to travel around the barricades (the barricade in the road user’s lane located in advance of the barricade located left of the center line).” rr. Part 6 of the OMUTCD includes an Ohio sign referred to as the Construction Arrow (W1-H16) which is used often to help accent a lane shift condition. It’s basically a straight arrow on a diamond shaped Warning sign, and the arrow is angled at 45 degrees upward to the right or left. Section 6F. 50.1 Construction Arrow Sign (W1-H16) Option: This sign may be used to help guide traffic through TTC zones. Standard: The Construction Arrow (W1-H16) sign (see Appendix C) shall not be used in place of the standard symbol warning signs. The sign shall be mounted so that the arrow indicates either an oblique left or right movement. Option: The sign may be located on the left or right side of the traveled lane. Support: An example of a situation where this sign might be used would be a lane shift, such as those shown in Figures 6H-31, 6H-32 and 6H-36. ss. In Part 6, the OMUTCD includes provisions for EXIT OPEN AHEAD and EXIT OPEN signs used in advance of an exit ramp (Figure 6H-41), to help provide confirmation for approaching drivers that the exit is open and to help locate/identify the opening. tt. In Part 7, based on current ORC provisions relative to School Zones and the related speed limit, the OMUTCD does not include use of the WHEN CHILDREN ARE PRESENT and WHEN FLASHING plaques with the 20 mph School Zone signing. Typically, a DURING RESTRICTED HOURS plaque, or one with hours is used. Also, several of the Sections in Chapter 7B have been revised and rearranged from what is shown in MUTCD Chapter 7B to more closely reflect Ohio Code provisions for school zones. Basically, the ORC establishes the basic school zone based on property lines of the school, establishes specific provisions where those limits can be extended (with ODOT approval), and sets the speed limit at 20 mph in a School Zone. uu. In Sections 7B.14 and 7B.15, the following provisions have been added in the OMUTCD for the School Bus Stop and Turn Signs (green Arial text is Ohio-only): Standard: These signs shall be erected only on the basis of a traffic engineering study and after the school transportation officials have confirmed the need for the stop. Guidance: 8 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 The need for these signs at existing locations should be reevaluated periodically. vv. In Section 7C.03, the OMUTCD recommends that “When the SCHOOL marking is used, it should be placed at least 100 feet in advance of the School Zone.” ww. In Section 8A.05, the OMUTCD includes the following additional Standard: “When a grade crossing is removed, the space previously occupied by the rail bed shall be filled with the same material that comprises the road or highway at the crossing.” xx. Provisions for installation of STOP signs at railroad grade crossings are addressed in ORC Section 4511.61. yy. As noted in OMUTCD Section 8B.07, use of an EXEMPT sign at a crossing must be approved by the Public Utilities Commission of Ohio. zz. Section 8B.10 of the OMUTCD provides that (green Arial text is Ohio-only): Section 8B.10 TRACKS OUT OF SERVICE Sign (R8-9) Option: The TRACKS OUT OF SERVICE (R8-9) sign (see Figure 8B-1) may be used at a grade crossing instead of a Crossbuck (R15-1) sign and a Number of Tracks (R15-2P) plaque when the abandonment of the railroad tracks has been approved by the regulatory authority with statutory authority, but only until such time that the tracks are removed or covered and the space previously occupied by the rails filled with the same material that comprises the road or highway at the crossing. Standard: When tracks are abandoned, traffic control devices, signal heads and gate arms shall be removed. The R8-9 sign shall be removed when the tracks have been removed and the space previously occupied by the rail bed filled with the same material that comprises the road or highway at the crossing or when the grade crossing is returned to service. aaa. Based on the ORC, provisions in Part 8 that address placement of the stop or yield lines at a railroad grade crossing indicate that the line should be placed “no closer than 15 feet nor more than 50 feet in advance of the nearest rail.” bbb. Due to some concerns about possible proliferation of this type of signing, in Section 9B.06 the OMUTCD includes some additional text (green Arial text is Ohio-only): Section 9B.06 Bicycles MAY USE FULL LANE Sign (R4-11) Support: ORC Section 4511.55 addresses operating bicycles and motorcycles on a roadway (see Appendix B). Generally, a bicyclist is required to ride as near to the right side of the roadway as possible, unless it is unsafe or impractical to do so. Guidance: Use of the Bicycles MAY USE FULL LANE (R4-11) sign should be based on engineering judgment. Option: The Bicycles MAY USE FULL LANE sign (see Figure 9B-2) may be used on roadways where no bicycle lanes or adjacent shoulders usable by bicyclists are present and where travel lanes are too narrow for bicyclists and motor vehicles to operate side by side. The Bicycles MAY USE FULL LANE sign may be used in locations where it is important to inform road users that bicyclists might occupy the travel lane. Section 9C.07 describes a Shared Lane Marking that may be used in addition to or instead of the Bicycles MAY USE FULL LANE sign to inform road users that bicyclists might occupy the travel lane. 9 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 Guidance: When the Bicycles MAY USE FULL LANE sign is used, the start and end of the section determined to warrant the signing should be marked with BEGIN (R3-9cP) and END (R39dP) plaques. 11. 12. 13. 14. 15. 16. 17. 18. ccc. OMUTCD Section 9B.09 allows an Option for an 18 x 18 inch No Bicycles sign when used on a sidewalk. ddd. Appendix B of the OMUTCD includes copies of ORC sections that have been referenced in the text. The user may still have to go on-line to check for the latest version of a particular Code section, but the information being available directly with the Manual is often very helpful. eee. The OMUTCD includes a Sign Index (Appendix C) which users have found very helpful. It depicts a picture of every sign shown in the Manual, with the code number and the primary Section reference for it. On page 14, Chapter 2, item 32c and d: We are preparing a response to a recent inquiry related to NCHRP 20-6, Study Topic 19-03, Effect of the MUTCD on Tort Liability of Government Transportation Agencies. It appears that this study should help your effort with addressing these questions. On page 14, Chapter 2, item 34c: Agree that use of the on-line versions of the Manuals is greatly increasing. At this point, however, a lot of our users in Ohio, e.g, village and township officials, etc., don’t always have easy access to computers and printers that can handle accessing and downloading large Manual files. Electronic versions can certainly make it easier to quickly find some things, but unless you have multiple screens available it can also make it more complicated to review multiple pages in the Manual (the paper form of the OMUTCD is still a loose leaf and 3-hole punched). Although the OMUTCD Parts and Chapters are bookmarked to help with access on-line, to really take advantage of the search capabilities for the electronic versions, you need to set up the hyperlinks and tags mentioned in the VSP, and that takes time we have not yet had. On page 22, Chapter 2, item 76, line 42: Recommend adding “and establishes legal standards and guideline” after “free to anyone.” On page 24, Chapter 2, item 77i: The public also uses the Manuals as a reference when they want to fight a ticket or bring a problem to the attention of the highway authority; and businesses use the Manuals for reference when they want to approach highway agencies about access and signing concerns. On page 37, Chapter 3, item 529, line 42: Recommend trying to avoid the “his/her” nomenclature. Consider stopping the sentence after “no choice.” On page 38, Chapter 3, item 530b: It will probably take a while to train people that sign size isn’t part of its “appearance.” On page 39, Chapter 3, item 533 (and others): At least initially, this seems to be potentially the most controversial aspect of this VSP proposal, and will probably take the most effort to retrain us all on the subtle differences. While it could help to have a way to try to express the subtle differences intended, and probably understood by most in the industry, with some provisions, actually making official distinctions between these words may take a lot of time and effort – and in some cases might cause more confusion. In general conversations, it is not uncommon for “shall” and “must” to be viewed as having the same meaning, and one often hears “should” and “ought” used interchangeably. Also, it may be hard to convince someone that when you tell them that “this is the preferred alternate” or the “preferred device” that it isn’t necessarily also the “recommended” one. On page 41, Chapter 3, item 536d: In discussing Options and the term “may,” it would be helpful to clarify just how much leeway is intended. This term has led to many discussions over the years that range from you can chose whether to use a device, but if you do, it has to be the one shown in the Manual; to, you can choose whether to use a device and what device to use, regardless to what is 10 Comments from Ohio Department of Transportation Draft 20-Year Vision and Strategic Plan for the MUTCD (7/18/13) 10/11/13 19. 20. 21. 22. 23. shown in the Manual (i.e., we’re showing just one of a number of possible alternatives). If the Option is shown as a modifier for a “should” or “shall” condition in the Manual, is it intended that that is the only exception, or just one of possibly many? On page 43, Chapter 3, item 538, line 38: Recommend adding “electronic” in front of “smart tags.” On page 46, Chapter 3, item 546a: We agree with the idea of limiting the number of items in a single rulemaking. They were much easier to handle back when they were usually just maybe 2050(?) individual proposals, at most twice a year. No more than 100 items may be a good starting place. Unfortunately, it also depends on what is being proposed. On page 46, Chapter 3, item 546b: To allow for a thorough review of proposed revisions to the national MUTCD, we agree that a review cycle that normally allows time for a proposal to be discussed at two NCUTCD meetings is appropriate. On pate 48, Chapter 3, item 553: As more of our manual users gradually become able to access the material on-line, perhaps a new Traffic Control Devices Handbook (on-line?) could be used to publish “preferred practices” as well as some of the other information that may be removed from the current MUTCD eventually. As noted in the draft, at this point, as a practical matter there is various material in the Manual (MUTCD or OMUTCD) that could be relocated out of it, if it weren’t for the fact that it’s more convenient for the Manual user to have it in one place – and much less expensive than having to purchase several manuals from different sources. On page 49 – We concur with the Recommended Strategic Plan. 11