[MassHistPres] federal regulation of street name (and maybe LHD) signs.

[Dennis De Witt]

Thanks to two who posted the following on the FHWA comment site -- only comments posted through 1/10 are up thus far.

Dennis De Witt

Brookline's historic (ca. 1937 - 1945) cast aluminum street signs are numerous and consistently designed and placed at intersections throughout our primarily residential community. There are approximately 500 signs remaining, which are primarily located on low volume, low speed residential streets. Their consistent design of raised black all cap letters on a silver ground provide a highly legible source of information to the traveling public, which are easily read at a more than adequate distance. Our streets are consistently well lit at night with overhead street lights, providing adequate illumination to the street signs. Therefore, Brookline's historic street signs provide safe, consistent and highly legible street name information. The MUTCD does not dictate the provision of street name signs. It also allows for local exemptions to the letter height and retroreflectivity guidance. Therefore, the Town of Brookline respectfully requests that an exemption be granted for its historic cast aluminum street name signs. These signs contribute significantly to the historic character of our historic street car suburb and they have been found to be eligible for listing in the National Historic Register. As a professional transportation and urban planner, I recognize their role as both a functional, safe informational aid to travelers, and as an integral part of the fabric of our community's public realm.  
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FHWA recently again changed the MUTCD to require a "Capital/Lower-Case" font for greater legibility. To avoid the great expense of changing local street signs when municipal administrations are clearly short of funds, perhaps each could provide an inventory of the legibility of their street signs and pledge to replace illegible or failing signs with the new design as they undertake their maintenance. 

I would also plead that historic street signs in National Register Districts be given special exception to this rule. They are part of what defines a place's character, and unless visible unsafe, should be allowed to remain and to be replaced in kind.

Thanks for your attention.

On Jan 7, 2011, at 1:30 PM, Dennis De Witt wrote:

> Here is an issue that could affect your town financially and as a preservation issue (and potentially as an LHD identification sign issue) -- and here's an opportunity to comment.
> 
> For a little background . . . 
> 
> All road signs follow the complex Manual of Uniform Traffic Control Devices (MUTCD) issued by the Federal Highway Administration (FHWA) and adopted, sometimes with amendments, by the states.  (If not adopted the state looses money).  The MUTCD's regulations are divided between required "Shall" items and recommended "Should" items.  Often highway engineers and DPWs treat everything as a "shall".
> 
> Technically, there is no requirement to have street name signs -- that is just assumed -- e.g. the old, (and allowed), yankee tradition of not naming the major street you are on, just the side streets.  (You are on it, so you know what it is!)
> 
> Many street name signs have recently been replaced by larger signs with 6" lettering.  (This larger lettering is not required on slower speed residential streets but most DPWs use the same size everywhere.  Although not required, typically these signs are all capital letters.  Often to keep them a reasonable length, less legible "condensed" (squeezed together) type faces are used.  
> 
> Therefore FHWA recently again changed the MUTCD to require a "Capital/Lower-Case" font for greater legibility.  
> 
> That lead to widespread protests because of the cost of changing all of these recently replaced signs.  In response the FHWA opened a public comment period through 1/14/11.  It has received hundreds of negative comments from DPWs and citizens alike.  These boil down two two issues 
> a) unfunded and very expensive mandate at a time when no one can afford them 
> b) a very widespread popular perception (correct or not) that CLC is not as legible as all caps
> 
> Many of the minority of favorable comments have been from Minnesota.  3(M) guesses who makes the reflective material specified exclusively for these signs.
> 
> As you may know, there are a few locations with historic street name signs.  Nantucket has wooden ones.  Apparently there are some Arts & Crafts ones in the Colony Hills area of Longmedow.  Brookline has about 500 surviving historic cast aluminum street name signs primarily dating from ca. 1937 to WWII.   Lower Marion Township, Pa. (Philadelphia's "Mainline" suburbs) may have the only other substantial set of cast metal street name signs in the US. -- designed around 1900 by Mary Cassatt's father (a government reformer and president of the Pennsylvania RR).   
> 
> Brookline has been in communication about this issue for years with folks in Nantucket, Lower Merion, and a few other places.  
> 
> Brookline's signs have been recognized as being National Register eligible within its Cottage Farm NR Historic District.  
> 
> For those with newer distinctive street name signs in LHDs -- this increasingly restrictive approach to regulation might someday affect your choice of colors and use of neighborhood identifying "toppers"
>  
> Those favoring local control the historic signs are encouraged to post comments to the Federal Register site.   The comment period is through 1/14/11. 
> 
> The comment site is:
> http://www.regulations.gov/#!submitComment;D=FHWA-2010-0159-0001
> 
> Historic New England (formerly SPNEA) has posted the following comment
> I write to request an exemption from the MUTCD letter height and retroreflectivity requirements for historic street name signs that have been determined to be National Register eligible, including meeting as a class the 50 year age requirement for National Register listing. Such signs specifically would include the Brookline, MA cast aluminum street name signs, of the type originally made in that town's foundry between ca. 1937 and WWII. Founded in 1910, Historic New England protects through ownership and preservation easement 300 buildings in 5 states, and the historic character of the neighborhoods in which these structures are located is better preserved and indeed enhanced by the retention of historic street furniture, with the street name signs especially prominent and visible.
> 
> Other comments posted specifically relating to historic street name signs include the following:
> 
> I am strongly opposed to replacing the historic street signs in Lower Merion Township.  The existing signs  . . . are part of our cultural heritage.
> 
> We should maintain our current street signs, rather than wasting money on new (very unattractive) signs.
> 
> "If it ain't broke, don't fix it!"
> 
> You are trying to tell us that the signs in MY small neighborhood that have streets that DO NOT EVER receive Federal aid are unsafe?
> 
> Lower Merion Township’s original street signs were designed by Alexander Cassatt and made of cast iron. They are part of our HISTORY. 
> 
> Historic or unique street naming signs should be left to local communities and not regulated unless they are . . . a real distraction to drivers. While traffic signs should likely be nationally standardized, it is hard to argue that the street name sign is a serious safety issue in the day of GPS Navigation. For the most part, street name signs are a matter of aesthetics and convenience. Why should the Federal government get involved in the size and shape of our local town street name signs . . . 
> 
> Lower Merion Township in Pennsylvania was settled by William Penn in 1625. The Township became a First-Class township in Pennsylvania in 1900, one of the first in the Commonwealth. Preservation of our built history is extremely important here. Our distinctive cast iron street signs, first erected in 1915, have been a symbol of our history which distinguishes us from neighboring towns. These signs are easy to read, sturdy, and permanent. We wish to keep them for the majority of our streets, even if regulations require modern reflective signs to be placed at major intersections. 
> 
> Lower Merion Township, Montgomery County, Pennsylvania, possesses historic cast iron and cast aluminum street signs mounted on ornamental cast iron posts. These street signs are character defining objects in our community and have contributed to the quality of life in our neighborhoods for nearly 100 years. Furthermore, our existing street signs have endured for nearly 100 years and are projected to last hundreds of more years, as opposed to the ten year expected service life of the signs mandated under the MUTCD. Furthermore, we oppose our Township having to spend an estimated $300,000 on street sign replacement currently mandated by the MUTCD.
> 
> We respectfully request that the requirements in the MUTCD pertaining to the replacement of existing street signs with new street signs meeting MUTCD standards be eliminated, or that an exception be made for historic street signs.
> 
> 
> 

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