|FHWA Policy Memorandums|
A number of conclusions can be drawn from the experience in administering the provisional use of the Clearview font. First, it is clear that there is an impact to allowing multiple fonts in sign design and manufacture. These impacts are evident from a significant amount of misunderstanding surrounding the appropriate or acceptable use(s) of the Clearview font that was reported in response to the Request for Information. To this end, the uniformity and standardization in traffic control devices that was established to help road users easily and instantly recognize and react to cues along the road also help the designers, manufacturers, and managers of these devices ensure that they are designed with consistency to achieve that purpose. Second, when implemented in accordance with the terms of the Interim Approval and the Design and Use policy, sign sizes will increase when the Clearview font is used in place of the Standard Alphabets. In other words, the font cannot simply be "substituted" into a sign layout or standardized template without many adjustments being made to the sign layout that affect readability. Third, there are additional costs associated with the use of the Clearview font and, thus, an inherent cost savings associated with the termination of the Interim Approval. These additional costs are evident in larger sign sizes, additional staff time required to educate and re-educate others in acceptable and allowable uses of the font due to its more nuanced criteria, and costs for the add-on software. While a few early adopters report being furnished complementary licenses for the font software by its developer, this was not the case for the majority of the States that adopted the font, nor would it have applied to other entities involved in the sign design and fabrication processes, such as design consultants and sign manufacturers that would then be required to purchase the software because the client agency had specified Clearview.
In addition to the direct impacts of the use of the Clearview font, several conclusions can be drawn about the overall processes used to develop, issue, and rescind Interim Approvals, as well as communication and outreach to stakeholders. These are discussed in this Section.
No new information was submitted to the RFI that would indicate Clearview font provided superior legibility over the Standard Alphabets. Similarly, none of the additional information addressed the shortcoming of the alternative letter style in regard to its limited applicability or the limited scope or focus of the past or more current research efforts.
When FHWA issued the termination for the IA-5, it believed that some level of understanding, at least among the State-level agencies, existed in the two years since issuing new approvals had been suspended. There had been no new requests from State-level agencies in the previous seven years. Only one new request had come from a local agency in 2014. At that time, FHWA informed that agency that further approvals would not be granted pending a decision on the long-term status of Clearview. In addition, FHWA reported at one or more of the semi-annual meetings of the NCUTCD and the annual meeting of the American Association of State Highway and Transportation Officials' Subcommittee on Traffic Engineering that the long-term status was being evaluated and a decision would be forthcoming. All States, as well many of the professionals involved in sign design and manufacture, are represented on one or both committees. Some of these actions are noted in the timeline provided in Table 2.3.
The termination of the Interim Approval for Clearview has been characterized as "abrupt," initially by one State department of transportation in its correspondence to FHWA. This characterization then proliferated in proposed legislation and news media when the correspondence was shared concurrently with other sources. However, the possibility of termination was evident through the following:
The FHWA also published an advance notice of the termination in the Federal Register in an effort to be transparent and reach the broadest possible audience. The purpose was to be clear to agencies what the reasons were for the termination and how the termination was expected to be implemented, offering agencies as much discretion as possible.
The process by which Interim Approvals are issued has evolved over the fifteen years that the Interim Approval provision has existed in the MUTCD. Normally, new Interim Approvals are issued through a memorandum to the FHWA's Federal-aid division offices, which then communicate that information to the States. This part of the process has not changed. However, in the time since this Interim Approval was issued, FHWA has learned that there is a high expectation, almost a perception of a guarantee, by State and local agencies that the provisional devices will be adopted in the next MUTCD. Unfortunately, the Interim Approval process, while designed to accelerate innovation, also provides the opportunity to gain additional experience with the provisional device. While many Interim Approvals were eventually adopted in the MUTCD, the provisions were revised, refined, and even limited based on the experience gained during the period of interim use. In essence, Interim Approvals, to some extent, serve as another level of experimentation but with much less control than an official experiment27 would involve. This evolution is not very different from the way that the provisions for a particular device might change from one edition of the MUTCD to the next: additional practical experience is gained with a successfully tested concept by having it deployed in practice. The purpose of updating the MUTCD on a periodic basis is to address not only new items, but also existing concepts that have demonstrable effects on traffic safety and operation. These effects might be positive or negative. Interim Approvals have been and will continue to be evaluated as a result of this experience to ensure that future Interim Approvals have the rigorous data needed to support inclusion in the MUTCD. Potential future procedures include minimum general thresholds and an appropriate level of analysis of the available data. These procedures had already evolved and been instituted since IA-5 was issued.
At the time of the termination of IA-5, no Interim Approval had been rescinded. Therefore, FHWA had no experience with taking such an action. Interim Approvals are not published in the Federal Register. Rather, new Interim Approvals are issued through official memorandum that is then distributed through the Federal-aid Highway division offices and made available to the public-at-large on the MUTCD Web site. A similar approach was taken with the first rescission of an Interim Approval. Because it involved a termination, the additional step of publication of an advance notice in the Federal Register was taken so it could more broadly reach those affected. As the notice was advance notification of a decision based on the twenty or more years of independent research efforts that had failed to accomplish its initial goal of "replacing the 40-year-old guide sign font with a new font called Clearview," did not involve a rulemaking action, did not require replacement of existing infrastructure, and was at least cost-neutral, FHWA did not solicit public comment.
There is no question that the presence and availability of two fonts with differing criteria have resulted in significant confusion among transportation professionals. The termination streamlined the design and specification processes by removing this complexity and confusion with this alternative that was not able to be resolved through issuing guidance as FHWA had done for several years. The termination reduced the burden on the Federal government by minimizing the extensive technical support, in the form of responses to public inquiries from State and local jurisdictions, required to sustain two standards. As indicated by several comments to the RFI, similar burdens on the States and others were reduced by minimizing the additional associated technical support to staff and local jurisdictions.
The MUTCD currently allows the use of fonts other than that Standard Alphabets under limited conditions. This flexibility is limited to Community Wayfinding signs found in urbanized locations that direct travelers to local points of interest that are not major destinations. Rather, the destinations listed are key civic and public institutions within the localized area. Each community's designs differ and are unique, but are contained to some extent by the MUTCD provisions that address contrast ratio between legend and background colors, size, and amount of legend. Further, their placement is also limited such that they do not obstruct or interfere with other higher-priority traffic control devices. These signs cannot replace standard guide or other types of signs, but can be used in addition to those in order to direct travelers to sites for which signs are not normally provided.
Any future research that examines alternative sign fonts should compare all letter styles studied using the same general proportion and letter heights, as well as intercharacter and line spacing to control variables and ensure true comparability in results. A predetermined objective of completely replacing an existing standard, as was most often the case with Clearview research, should be avoided to maintain objectivity in the results. By keeping the objective to improving legibility or other viewing factors independent of font should ensure objective results that can appropriately inform future direction on improving the effectiveness of traffic control devices. The impact of establishing and maintaining separate standards for each alternative font, and their impact on consistency in sign design and appearance, should also be major factors.
United States Department of Transportation - Federal Highway Administration