There have been several developments at the federal level that are making it easier for communities that want to design safer, more complete streets. First, FHWA has issued new street design guidelines which are much simpler. Second, FHWA issued an announcement last week making clear that it does not have regulations or policies that require specific minimum Level of Service (LOS) values for projects on the National Highway System. As we well know from our experience in Lee County, LOS is often used to halt plans to make streets safer for everyone or boost economic development by narrowing lanes, adding bike lanes, mid-block crosswalks, bulb-outs, or other improvements. While these are two steps forward, FHWA is proposing to go in the opposite direction in its recently proposed performance measure for congestion, which is solely auto-focused. This is just a proposal so there's time to weigh in with your comments in opposition (see below for instructions).
Smart Growth America, one of BikeWalkLee's national partners and the umbrella organization for the National Complete Streets Coalition, wrote an excellent blog last week on these developments, which is shared below.
The Federal Highway Administration made two big moves this
last week to clear the way for states, metro areas, and local
communities to use federal dollars to design safer, more complete
streets.
Both of these updates are great news for anyone advocating for
streets that better meet the needs of everyone that uses them, as well
as better serving the goals of the surrounding community.
FHWA deserves a big round of applause for making these changes.
If you are working on a local transportation project and your DOT or
some other agency cites vague federal rules when refusing to build a
safe and complete street, show them the FHWA memo below. Their guidance
makes it extremely clear: there’s wide latitude to design streets to
best suit local needs, and old regulations that treat all roads like
highways have been rolled back.
Federal street design guidelines just got a lot simpler
Last week, FHWA finalized
new street design guidelines
that scrap the bulk of the criteria that local communities and states
must adhere to when building or reconstructing certain roads —
especially those with speed limits under 50 mph. Of 13 current design
criteria for certain roads under 50 mph, 11 criteria have been scrapped,
because, in FHWA’s words, they have “minimal influence on the safety or
operation on our urban streets.”
Until now, states or cities would have to go through an arduous
process of requesting an exception to do common sense things like line a
downtown street with street trees, reduce the width of lanes to add a
bike lane, or curve a street slightly to slow traffic and make it safer
for people in cars and on foot. (
This old post explains the change in more detail.)
The new criteria recognize that successful streets running through a
bustling downtown of any size need to be designed far differently than
rural highways connecting two towns or cities. They have to meet a far
more diverse range of needs than simply moving cars fast, and these
smart new guidelines reflect that wisdom.
Thousands of our supporters sent in letters to FHWA about this issue, and
FHWA listened. From the
final rule:
The FHWA received comments from 2,327 individuals and
organizations on the proposed changes to the controlling criteria. Of
these, 2,167 were individual form-letter comments delivered to the
docket by Transportation for America…The overwhelming support for
changes to the controlling criteria indicate that the changes will
support agency and community efforts to develop transportation projects
that support community goals and are appropriate to the project context.
The provisions included here for design documentation will result in
more consistent evaluation of exceptions to the adopted design standards
when controlling criteria are not met on NHS highways.
Even more encouraging, FHWA responded strongly to the handful of
state DOTs that sent in comments noting their desire to keep the old
design guidelines intact:
The FHWA finds that removing these controlling criteria
from application in low-speed environments is supported by research and
provides additional flexibility to better accommodate all modes of
transportation. No new controlling criteria are proposed at this time.
In their comments, FHWA affirmed that local communities should have
more leeway in how they design streets — after all, they know their
local needs best — and that research shows that the old guidelines made
it more difficult to accommodate all modes of transportation.
Vehicle speed- and delay-focused “level of service” metric is not a federal requirement
When planning a new street, reconstructing an old street, or
conducting traffic studies for new development, most transportation
agencies rely on a metric known as level of service or “LOS”. While
commonly accepted amongst many traffic engineers, it’s an outdated,
narrow metric that assesses how well a road performs only by looking at
the number of cars and the amount of delay experienced by vehicles.
If the only goal of your community’s streets is moving cars fast,
then level of service is the way to go. If your community also wants to
keep people safe, or allow people to walk, bike or take transit, or
support a vibrant downtown, then relying only on level of service isn’t
going to cut it. It’s like trying to decide if a new pair of pants will
fit by measuring the waist and ignoring the inseam.
Similar to the street design requirements that FHWA just scrapped,
level of service is often used to halt plans to make streets safer for
everyone or boost economic development by narrowing lanes, adding bike
lanes, mid-block crosswalks, bulb-outs, or other improvements. It’s even
been cited as a federal requirement in some cases. To those agencies,
planners and engineers, FHWA made an announcement on May 6 (emphasis
added):
We have received several questions regarding the minimum
level of service (LOS) requirements for projects on the National Highway
System (NHS)…FHWA does not have regulations or policies that require specific minimum LOS values for projects on the NHS.
The recommended values in the Green Book are regarded by FHWA as
guidance only. Traffic forecasts are just one factor to consider when
planning and designing projects. Agencies should set expectations for
operational performance based on existing and projected traffic
conditions, current and proposed land use, context, and agency
transportation planning goals, and should also take into account the
input of a wide cross section of project stakeholders.
This might seem like a minor clarification,
but FHWA just gave the green light to localities that want to implement a complete streets approach.
By making clear that there is zero federal requirement to use level of
service (and that there never has been), FHWA is implying that
transportation agencies should consider more than just traffic speeds
when planning street projects.
Changing policy is one thing but changing behavior is another,
however. Level of service is an instructive example. It’s never been a
federal requirement, but that hasn’t stopped transportation agencies all
over from relying on it. And though the design guidelines have been
radically pared back for most streets, that doesn’t mean that a state
DOT won’t continue to adhere to them as a matter of course.
Engaging with your city, metro planning organization and state DOT
will continue to be important for your community to realize its plans
for safer, complete streets.
Yet, USDOT is going the opposite direction on measuring congestion
Of course, these encouraging changes from FHWA stand in sharp
contrast with USDOT’s narrow, vehicle-focused proposal for how to
measure congestion. While FHWA acknowledges that “traffic forecasts are
just one factor to consider,”
the proposed rule from USDOT would measure congestion in a way that places vehicle speed and delay far above any other factors.
This would penalize places that have made it easier to avoid
congestion by making it easier to get around on transit, by foot or
bike, or through telecommuting. And it would have the effect of
rewarding places with long commutes that move quickly over places with
shorter average commutes that move slower.
We need to measure congestion in a way that lines up with these two very encouraging moves from FHWA.
Have you sent a letter yet? Join the nearly 2,000 people who have already told USDOT they can do better.
This post is crossposted from our Transportation for America program.
