|FHWA Policy Memorandums|
The FHWA received 27 docket comment letters, 24 of which were unique letters and 3 exact duplicates of other letters, plus an additional three unique letters in 2017 and 2018. The docket letter responses included a variety of affiliations: 9 from State departments of transportation (DOTs), 2 local agencies, 2 toll authorities, 3 national professional associations, 1 traffic engineering consultant, and 7 private citizens. Six commenters agreed with the termination, sixteen disagreed with the termination, and two commenters expressed no opinion on the termination but rather indicated that FHWA should conduct additional research and studies on font types. Three additional commenters, including one from a sign manufacturer, submitted letters in late 2017 and early 2018 stating that the interim use of Clearview should not be reinstated noting Congressional intent to do so at that time.
Of the nine State DOTs that submitted comments, seven disagreed with the IA Termination. One State DOT assumed, incorrectly, that using Clearview allowed it to avoid "making signs with the Standard Alphabets that are 16 percent wider and 16 percent higher" in order to achieve a 16 percent improvement in legibility distance, referring to an early study that suggested such an increase in legibility distance when using Clearview over the Standard Alphabets.23 Another State DOT indicated that, prior to the termination of IA-5, it had nearly completed a transition from Clearview back to the Standard Alphabets due to challenges the agency encountered when implementing Clearview, having gained practical experience with it over the previous ten years. The agency concluded that the use of the Standard Alphabets "ensures consistency of type across an entire sign panel, including positive and negative-contrast text, route shields, and other legend items." The detailed narrative of these issues that was provided addressed the "mixed message stemming from Clearview publicized as a 'superior typeface.' " The commenter attributed "[a]rticles and reports that implied Clearview was text was preferable for all sign types" to agency "time and resources [that] were consumed by the need to explain the reasons for" the limitations on the uses of Clearview to sign designers, even though the limitations were detailed in IA-5. The agency also provided cost information, reporting that the additional cost for the electronic Clearview font was $525 for each of its approximately 40 workstations [approximately $21,000] in addition to its basic sign design software. The remaining commenter did not provide an affiliation with a specific State; rather, the commenter identified as a State DOT Traffic Engineer. That individual stated that, "the limitations of the Clearview Interim Approval make it inefficient for designers, and increase the probability of incorrect designs and a lack of uniformity" and suggested that "FHWA should drive the process by pursuing independent research that determines how to optimize letter legibility, and that result should be the required alphabet."
Maricopa Association of Governments (MAG) and Maricopa County Department of Transportation (MCDOT) were the only local agencies to comment. MAG, the Metropolitan Planning Organization for the Phoenix, Arizona, metropolitan region, indicated that it had approved nearly $82,000 in funding for and promoted the use of Clearview font as a roadway safety improvement and, therefore, disagreed with the termination. MCDOT provided statistics regarding the number of signs, cost, and installation of signs using Clearview font. MCDOT suggested that costs were reduced because the new signs were smaller than the signs they replaced. However, a cost comparison was not provided and, in an investigation of the new installations, the newer signs were notably larger than the signs that they replaced. Further, it would not be possible for the newer signs to be smaller than the existing signs if the same height of Clearview lettering were used with its required letter spacing. MCDOT stated further that the new signs at major intersections, were, in fact, larger than the signs that they replaced. The increase in the size of the signs alone would have improved their conspicuity, regardless of the font used, likely contributing to the perception of improvement. In addition, the new signs at major intersections used mixed-case lettering where the signs they replaced used all upper-case letters and in a much smaller letter height. Either one or both of these changes would have improved recognition and legibility regardless of the selection of Clearview over the Standard Alphabets. Therefore, it is not appropriate to attribute the perceived improvements to Clearview. Neither agency provided information on how the use of Clearview improved safety.
The two toll authorities disagreed with the IA termination. The Pennsylvania Turnpike Commission indicated that it has installed guide signs with Clearview on a large portion of its network and, "[has] not received a single complaint nor have we been notified of any safety concerns regarding our signing policies as they relate to the use of the Clearview font." Similarly, the Central Florida Expressway Authority indicated that it has guide signs with Clearview font on over 90 percent of its system and has had "only positive experience." The Central Florida Expressway Authority stated that it was furnished a complementary license for the Clearview font software for use on its system. Neither agency provided data or other information on safety impacts.
Of the three associations submitting comments, the American Traffic Safety Services Association (ATSSA) agreed with the termination of IA-5. The Institute of Transportation Engineers (ITE), referencing the National Committee on Uniform Traffic Control Devices (NCUTCD) letter, disagreed with the termination, suggesting that FHWA either sponsor dialogue and debate with traffic control device human factors researchers on the subject or engage in a third-party independent review of existing Clearview research.
One traffic engineering consultant provided comments, which agreed with the IA termination. The commenter stated that even with the additional guidance that FHWA had issued, "there was still widespread inappropriate use of the font, which have traditionally not been issues with FHWA [S]tandard [A]lphabets in the past." The commenter explained an experience with attempting to purchase true-type fonts in both FHWA Standard Alphabets as well as Clearview from a commercial vendor. The commenter was informed that, although the company had digitized the Clearview font from the FHWA's published letter form details,24 the vendor was served with a cease-and-desist notification from the "owners" of Clearview stating that the company could not sell the font.
Seven private citizens responded to the docket but did not provide their company affiliation. Four of the citizens agreed with the termination, while two disagreed. One commenter, rather than agreeing or disagreeing with the termination, suggested potential tests to provide a better comparison between alphabet fonts.
Several agencies referenced the research described in Section 3.3 earlier in this report.
Three additional commenters, including a sign manufacturer, submitted letters in late 2017 and early 2018 stating that the interim use of Clearview should not be reinstated.
23 Early reports of significant improvement in legibility distance were refuted by subsequent studies that found variables had been confounded; these studies are discussed in Section 3.1 of this report. [Return to Note 23]
24 The FHWA has published the letter form details for both the Standard Alphabets and Clearview letters, which are in the public domain. The purpose publishing these details is so that the letters can be replicated with accuracy, including for use as an electronic font, and including for the purpose of selling the electronic font on the open market. In general, there are no restrictions on who may produce the traffic control devices adopted in the MUTCD, or under official experimentation or Interim Approval under the provisions of the MUTCD, including if the purpose is commercially market them. [Return to Note 24]
United States Department of Transportation - Federal Highway Administration