July 30, 2008
U.S. Department of Transportation
Dockets Management Facility
1200 New Jersey Avenue, S. E.
Washington D. C. 20590
Re: FHWA Docket No. FHWA–2007–28977 National Standards for Traffic Control Devices; the Manual on Uniform Traffic Control Devices for Streets and Highways; Revision
The National Association of County Engineers (NACE) appreciates the opportunity to respond to this docket. NACE is an integral sponsor of the National Committee on Uniform Traffic Control Devices and has had extensive input during the NCUTCD review of the NPA. The NCUTCD recognizes the need to revise the MUTCD on a timely basis to keep it up-to-date with current practices and technologies. However, the NCUTCD also believes that it is vital that the FHWA produce an MUTCD that is fully vetted by practitioners, even if more time is needed to revise and republish a proposed rule. After a careful review of the NPA and an assessment of its own docket comments, the NCUTCD believes that the changes to the NPA will be significant and justify further review before finalizing. In the interest of producing the best possible next edition of the MUTCD, the NCUTCD is recommending that the FHWA publish a Supplemental Notice of Proposed Amendments (SNPA) on the MUTCD prior to publication of a Final Rule. The SNPA should incorporate the FHWA responses to the docket comments received in response to the NPA and provide an opportunity for the public to assess how all of the changes to the NPA relate to each other prior to the Final Rule.
The National Association of County Engineers is in full support of the request for a SNPA. We are also in full support of the response submitted by the NCUTCD. After review and incorporation of all pertinent comments we believe a substantial change will be evident and warrant another review by all entities.
Many counties and state county engineer’s associations have provided input to the docket and we strongly encourage the FHWA to consider those comments. Many of the changes made to the MUTCD will have a profound economic effect on local agencies resulting in less money to otherwise maintain and reconstruct our infrastructure.
Sincerely,
A. R. Giancola, P. E.
Executive Director