Public Comment on Proposed Revisions to the Manual on Uniform Traffic Control Devices for Streets and Highways - Proposed Rule; Notice of Proposed Amendments to National Standards for Traffic Control Devices: Manual on Uniform Traffic Control Devices for Streets And Highways; Revision Docket Id: Fhwa-2020-0001 Regulation Identifier Number (Rin) 2125-Af85

10 Pages Posted: 17 May 2021 Last revised: 26 May 2021

See all articles by Sara C. Bronin

Sara C. Bronin

Cornell University - College of Architecture, Art & Planning; Cornell Law School

Gregory H. Shill

University of Iowa College of Law; University of Iowa College of Engineering, National Advanced Driving Simulator

Date Written: May 14, 2021

Abstract

This comment was submitted in response to a Notice of Proposed Amendments to the Manual on Uniform Traffic Control Devices (MUTCD). The MUTCD establishes national standards for certain aspects of road design and transportation policy. Our comment calls upon the MUTCD's owner, the Federal Highway Administration, to scrap the current review process and conduct a full rewrite of the MUTCD. We also call upon the FHWA to exercise its authority under the Administrative Procedure Act to issue an emergency rule withdrawing a method it sanctions for modifying speed limits, the 85th Percentile Method.

Keywords: transportation, law, policy, 85th percentile, speed, limits, equity, innovation, engineering, administrative, APA, highway, transit

JEL Classification: R40, R41, R42, R53, R14

Suggested Citation

Bronin, Sara C. and Shill, Gregory H., Public Comment on Proposed Revisions to the Manual on Uniform Traffic Control Devices for Streets and Highways - Proposed Rule; Notice of Proposed Amendments to National Standards for Traffic Control Devices: Manual on Uniform Traffic Control Devices for Streets And Highways; Revision Docket Id: Fhwa-2020-0001 Regulation Identifier Number (Rin) 2125-Af85 (May 14, 2021). U Iowa Legal Studies Research Paper No. 2021-24, Available at SSRN: https://ssrn.com/abstract=3846597 or http://dx.doi.org/10.2139/ssrn.3846597

Sara C. Bronin

Cornell University - College of Architecture, Art & Planning ( email )

Ithaca, NY
United States

Cornell Law School ( email )

Gregory H. Shill (Contact Author)

University of Iowa College of Law ( email )

Boyd Law Building
Iowa City, IA 52242
United States

University of Iowa College of Engineering, National Advanced Driving Simulator

2401 Oakdale Blvd.
Iowa City, IA 52242
United States

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