Interpretation Letter 2-603(I) - Letter Size and Design of Street Name Signs

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U.S. Department of Transportation
Federal Highway Administration

400 Seventh St., S.W.
Washington, D.C. 20590

November 30 , 2006

In Reply Refer To: HOTO-1

Mr. A. Thomas DeMaio
Commissioner of Public Works
Town of Brookline
333 Washington Street
Brookline, MA 02445-6863

Dear Mr. DeMaio:

Thank you for your October 30 letter to the Federal Highway Administration (FHWA) requesting an official interpretation of information contained in the Manual on Uniform Traffic Control Devices (MUTCD) addressing Street Name signs.

In your letter you describe the historic street signs with 4-inch cast aluminum raised letters that are installed in the community of Brookline, Massachusetts. The key question you asked is whether these signs can be retained without having issues of non-compliance and if there are issues of non-compliance, are there implications for the Town of Brookline? We know how important these signs are to the community. However, we regret to inform you that these signs are not in compliance with the MUTCD because all signs are required to be either retro-reflective or illuminated and the signs in the Town of Brookline do not meet either of these requirements.

Compliance with the MUTCD is required on any Federal-aid highway project in which Federal highway funds participate. Federal-aid projects cannot be opened to the public until conforming traffic control devices are installed and functioning properly. In addition to Federal-aid highway projects, there are also many State and local streets and highways that are not a part of the Federal-aid program. In these situations, each State has in place a highway safety program designed to reduce traffic accidents and resulting deaths, injury, and property damage. This program is established by each State in accordance with the highway safety program guideline 21 issued by the U.S. Department of Transportation. The guidelines provide that each State, in cooperation with its political subdivision, should have a program for applying traffic engineering measures and techniques to reduce the number and severity of traffic crashes, including the use of traffic control devices that are in conformance with the MUTCD. The program also includes provisions for the systematic upgrading of substandard traffic control devices and for the installation of needed devices to achieve conformity with the MUTCD.

In MUTCD Section 2A.08 it states: "Regulatory, warning, and guide signs shall be retroreflective or illuminated to show the same shape and similar color by both day and night, unless specifically stated otherwise in the text discussion in this Manual of a particular sign or group of signs. The requirement for sign illumination shall not be considered to be satisfied by street or highway lighting."

Street Name signs are considered guide signs and they shall follow the provisions in Section 2A.08. This means that the historic Street Name signs in Brookline, Massachusetts, must be either a retroreflective material or illuminated in such a manner that the shape and color are visible to the road user both day and night. Table 2A-1 and Table 2A-2 in the MUTCD provide various methods for providing sign illumination and retroreflection.

The lettering of Street Name signs is addressed in MUTCD Section 2D.38 and it states that on ground-mounted street name signs that are not on multi-lane streets, the letters should be at least 6 inches high where all capital letters are used, or you can use 6 inches upper-case letters with 4.5 inches lower-case letters. For local roads with speed limits 25 mph or less, there is an option provided that allows the use of 4-inch letter height and words such as Street, Avenue, Road, or NW may be 3-inch letter height. The letter size of ground-mounted street name signs discussed above was originally added to the MUTCD in January 1997. A 15-year compliance period was provided. This means the compliance date for increasing the letter size of all ground-mounted street name signs on roads that are not on multi-lane streets is January 2012. On multi-lane streets with speed limits greater than 40 mph, the lettering on ground mounted street name signs should be at least 8 inches in all capital letters, or 8 inches upper-case with 6 inches lower-case letters. This change to the MUTCD was adopted in November 2003 with a 15-year compliance period. This means the compliance date for increasing the letter size of all ground-mounted signs on multi-lane streets with speed limits greater than 40 mph is November 2018.

The color of Street Name signs is also addressed in MUTCD Section 2D.38 and it states that these signs should have a white legend and border on a green background. You are correct that this is a "should" condition and the FHWA recommends the colors white and green for use with Street Name signs. In specific situations, there may be a valid reason for using other colors for Street Name signs. If you have a special situation that may merit a color other than white on green, please let us know and we will consider your request. You are correct that the sign legend and background must be contrasting colors.

You also asked, "As far as retroreflectivity and the use of breakaway posts, the word "shall" is used. Are they required now and are they required by January 9, 2012?" The answer to the first part of this question is that signs are required to be either retroreflective or illuminated—meaning one or the other. This requirement is in effect now so there is no future compliance date for this. The second part of this question deals with the use of crashworthy supports as covered in MUTCD Section 2A.19 which states that ground-mounted sign supports shall be breakaway, yielding, or shielded if within the clear zone. This means that any of these 3 methods (breakaway, yielding, or shielded) are appropriate. The use of crashworthy supports was added to the MUTCD in December 2000. For roads with posted speed limits of 50 mph or higher, the compliance date is January 17, 2013. There is no compliance deadline on lower speed roads, but sign supports should be upgraded whenever the sign installation requires maintenance or replacement. Crashworthy supports should be used on all new installations.

The following are answers to the 4 specific questions at the end of your letter:

Can historic panels be kept indefinitely as long as they are in good condition?
No. All signs, including the historic panels, must be retroreflective or illuminated in such a manner that the shape and color are visible to the road user both day and night. In addition, the letter height on these signs has to be increased to 6 inch letters no later than January 9, 2012.
Is or will there be a waiver process available to communities for MUTCD standards?
No. The FHWA does not grant waivers to the MUTCD.
Is there paint or other treatment that can be applied to our existing historic sign panels to achieve retroreflectivity? No. However, the historic sign panels may be displayed below the new Street Name signs.
What is FHWA's position on concerns of flying debris from breakaway posts when they are used in neighborhoods and urban areas? Breakaway supports are designed to prevent the condition of flying debris because the post is either designed to bend at the base so it remains intact, designed with a slip-base, or designed with breakable couplings.

We appreciate the opportunity to provide this interpretation to you. For recordkeeping purposes, we have assigned the following official ruling number and title to your request: "2-603(I) - Letter Size and Design of Street Name Signs." Please refer to this number in any future correspondence with our office. You may also contact Ms. Linda Brown of my staff at 202-366-2192 or e-mail Linda.L.Brown@dot.gov.

Sincerely yours,

/s/ Anthony T. Furst

Anthony T. Furst
Acting Director, Office of Transportation Operations