Complete Streets at the municipal level: A review of ......2017/02/01 · iCity: Urban Informatics...

Complete Streets at the municipal level: A review of American municipal Complete Street Policy

Gregg, Kelly and Paul Hess

iCity: Urban Informatics for Sustainable Metropolitan Growth

A project funded by the Ministry of Research and Innovation of Ontario through the ORF-RE07 Program and by partners Cellint Traffic Solutions, Esri Canada, IBM Canada, Waterfront Toronto, the City of Toronto and the Region of Waterloo.

Report #17-02-01-01

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By: Kelly Gregg and Paul Hess

Kelly Gregg ([email protected]) is a PhD Candidate in Planning in the Department of Geography and Planning at the University of Toronto. Her research focuses on pedestrian environments, both in the post-war and contemporary context.

Paul Hess ([email protected]) is an Associate Professor in the Department of Geography and Planning at the University of Toronto where his research and teaching focus on pedestrians, streets, and public space.


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Abstract: The Complete Streets Act of 2009, preceded a proliferation of municipal level complete streets policy across United States. These policies aim to challenge auto-centric street design standards in favour of ‘complete streets’–that are safe for all users and abilities. The proliferation of ‘complete streets’ policy is noteworthy progress in addressing the needs of non-motorized street users and sustainable transportation. However, research that critically and systematically analyzes the ability of the policies to guide street design decision-making is limited. We address this gap, though a review of municipal level Complete Street Policy. We sampled a total of 113 municipal level complete streets policies, from The National Complete Streets Coalition’s database. We reviewed the policies with interest in understanding the qualitative content, probing definitions, and the implications for design and implementation. We argue that most municipal Complete Street policies do not address negotiating trade-offs within the street right of way. Policies often remain broad and defer to general and idealistic goals of safely accommodating all user types regardless of ability, without recognizing an implicit hierarchy of accommodation. This study is limited to analyzing the content of the policies alone; we argue it is necessary first step in critically thinking through Complete Street policy development and examining if current municipal policies are able to successfully challenge the primary accommodation of automobility. Without a critical analysis, there is a risk of replicating policy that is ineffective at producing streets that safely accommodate non-motorized users, or only provide minimum accommodations for bicyclists and pedestrians.

Key words: Complete Streets, Municipal Policy, Complete Street Policy, Transportation Policy Non-Motorized Transportation


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1. Introduction

For nearly one hundred years US planning and engineering concepts, guidelines, and

standards have been developed to prioritize automobile movement on public streets (Brown,

Morris, & Taylor, 2009; Golub, 2015; Hebbert, 2005; Hess, 2009; McCann, 2013; Norton, 2015;

Smith, Reed, & Baker, 2010). This is rapidly changing, however, with over 900 complete streets

policies established across the United States (US) since 2004. The Complete Streets (CS)

concept promotes safe, accessible streets for all users including non-motorized users, primarily

cyclists and pedestrians. In the US specifically, CS are articulated and promoted by the National

Complete Streets Coalition (NCSC), a non-profit organization that has logged policies developed

by the US federal government, 36 of 50 state governments, 76 regional organizations including

Metropolitan Planning Organizations, and over 650 municipalities. Of the 820 municipal level

policies from NCSC’s database, this paper examines 113 municipal CS policies to assess: the

scope, the definition and operationalization of CS concepts, and, especially, how the policies

guide trade-offs between street users and functions. There are seven different municipal level

policy types recognized by NCSC, ranging from ‘executive order’ to ‘design manual’, the

sample focuses on ‘legislation’, ‘resolution’ and ‘policy’ as these types are representative of

eighty one percent of municipal level policy in the US. While plan and policy evaluation are

worthwhile areas of research to access the implementation of CS, most municipalities in the US

do not produce CS plans or design guidelines, and most are also in the infancy of implementing

CS networks. Together ‘plans’ and ‘design manual’ make up only eleven percent of municipal

level policy in the NCSC database. Though this study is limited to analyzing the content of the

policies alone, we argue it is necessary first step in critically thinking through the Complete

Street policy development and examining if the majority of policies, at the municipal level, are


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able to successfully challenge the primary accommodation of automobility and provide safe,

accessible, sustainable, transportation alternatives.

At its core, the CS concept fundamentally challenges the conventional motor-vehicle

oriented regime of street design (McCann, 2013; Vega-Barachowitz, Koonce, & Flynn, 2013;

Winters, Mitra, Smith Lea, & Hess, 2016). According to McCann, a principal founder of NCSC,

“the Complete Streets movement is at its heart a policy initiative that seeks to change the

way all roads are built…” (p. 21). Scholarly literature assessing CS however, is surprisingly thin.

While related literature on non-motorized, sustainable, transportation such as walkability and

cycling is numerous, articles focusing solely on CS number only in the dozens, with almost half

these in the Journal of the Institute of Transportation Engineers (ITE Journal). Most of the

articles in ITE Journal advocate for CS, are case studies, or “how to” guides (e.g. Burden &

Litman, 2011; Laplante & McCann, 2008; Sears, 2014). While very useful for advocates and

practitioners, these articles fall short of a scholarly assessment of CS policy. Outside of the ITE

Journal, scholarship specifically addressing CS is sparser yet, and most studies are very case

specific. For example, Shapard & Cole (2013) examine the costs of adding sidewalks and cycle

lanes to street cross-sections in Charlotte, North Carolina; their results show only small increases

in cost if lane widths are also reduced. Another study found that the probability of a community

adopting a CS policy is correlated to state obesity rates, the percentage of people who walk or

bike to work in a state, and whether bordering communities also have CS policies (Moreland-

Russell, Eyler, Barbero, Hipp, & Walsh, 2013).

A broader area of research addresses multimodal level of service (LOS) metrics for

evaluating CS designs. Where conventional LOS measures capture motor vehicle roadway

congestion or intersection vehicle throughput, recent tools such as the Bicycle Environmental


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Quality Index and the Pedestrian Environmental Quality Index measure non-motorized

transportation environments. Bronzen et al. (2014), examined four common-multi-modal LOS

tools that use different approaches, from checklists of street features, to the data analytic-heavy

multimodal LOS developed for the 2010 Highway Capacity Manual (National Research Council

(Estats Units d’Amèrica) & Transportation Research Board, 2010). The study found that the

tools produce different results for the same street section and capture only major differences in

right-of-way configuration such number of travel lanes. Both Elias (2011) and Carter et al.

(2013) focus on the Highway Capacity Manual’s multimodal LOS. Elias found that bicycle lanes

did improve bicycle LOS, however the resulting motor vehicle lane reductions increased traffic

density and negatively impacted pedestrian LOS. This shows that trade-offs between modes are

occurring. Carter et al. also note reduced pedestrian LOS with decreased number of traffic lanes.

They identified other counter-intuitive outcomes including the finding that bus lanes did not

improve transit LOS. They conclude that the tool is not sufficient “to provide a complete picture

of street performance.”

Henderson (2011) argues that the impact of multimodal LOS metrics are “debatable,”

however, the article predates the discontinued use of vehicle LOS for environmental review in

2014 by the State of California. Incomplete Streets (Zavestoski & Agyeman, 2015a), an edited

collection, also focuses on the politics of CS, and suggests that CS “narratives, policies, plans,

and efforts...might be systematically reproducing many of the urban spatial and social

inequalities and injustices that have characterized cities for the last century or more” (p. 306).

Many chapters focus on relationships between CS projects and gentrification (e.g. Golub, 2015;

Hoffmann, 2015; Miller & Lubitow, 2015) or identify that CS has the potential to lower the

mobility of low-income, car-dependent households (Chapple, 2015).


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None of this work, however, carefully examines the specific content of CS policies. We

do so here by examining municipal level CS policy. Our analysis aims to understand the ways

CS are defined, both explicitly and in operational terms, the physical elements that are identified

to distinguish CS from other street types, and finally, if negotiation of trade-offs between

motorized and non-motorized user types in the right of way (ROW) is recognized, how the

policy guides the trade-offs.

2. Methodology

NCSC’s annually evaluates new CS policies (National Complete Streets Coalition, n.d.).

They rate policies for their inclusion of “ten ideal elements” including: vision and intent, modes

and users, project types, exceptions, network considerations, implementation and related

agencies, design considerations, context sensitivity, performance measures, and steps toward

implementation. Each element is given points according to a weighted checklist. The number of

modes covered, and the inclusion of an implementation plan are given the highest weights,

comprising 20% each of the total score (p. 21-22). NCSC works directly with jurisdictions to

shape and promote the development of CS policies, unsurprisingly from this collaboration, the

median scores for their annual policy review has increased over the last decade.

Our CS evaluation differs from NCSC in that we sampled policies across the decade. Our

method focuses on understanding the qualitative content of policies, probing definitions, and

thinking through the implications for design and implementation. NCSC makes it clear that CS

policies do not, in themselves, specify how CS will be designed and implemented. This occurs

through changing agency practices, incorporating public processes, rewriting comprehensive

plans, developing pedestrian and bicycle plans, developing new design guidelines, rewriting


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subdivision regulations, and changing the other types of working policies and practices that

constitute and shape day-to-day street design, building, operations, and maintenance. It is critical

to keep this point in mind, but we argue that how policies conceptualize CS is critical to framing

these practices.

Policy Sample

Policies were sampled from the existing NSCS inventory as of January 2016. Policies are

self-reported to the NSCS by municipalities or collected by NSCS directly. The sample and

analysis focuses on municipalities because they hold the most responsibility for the design and

operation of urban streets. The sample is stratified across two dimensions: policy type as

identified by NSCS, and city size.

CS literature doesn't distinguish differences in policy types. However, at the municipal

level, there is a diversity of policy types ranging from detailed design manuals, to executive

orders or resolutions that support for CS concepts, but have little or no legal weight. The NSCS

classifies the following policy categories: design guidelines, executive orders, internal policies,

legislation, plans, policies, resolutions, and tax ordinances (National Complete Streets Coalition,

n.d.). How policies legally differ by type can be unclear however, for example ‘policy’ and

‘legislation’ categories are particularly ambiguous with respect to each other. The diversity of

policy types may also represent CS policy development overtime, within a municipal

government. For example, the municipality may first adopt a non-binding ‘resolution’

establishing ‘consideration’ for CS principals, and later establish, legally binding ‘legislation’.

Design guidelines are the most detailed types of policy. They guide the physical design

and implementation of CS for a specific municipality. Design guidelines are not legally binding,


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require extensive resources to develop, and tend to be developed only by the largest

municipalities. NCSC collects design guidelines for their policy database, however do not

include them in their annual policy evaluation. We include them in our analysis however,

because they are key to understanding how CS are defined from a design perspective. In addition

to the design guidelines, our sample includes ‘legislation’, ‘resolutions’, and ‘policies,’ as these

policy types represent about 80% (n=670) of municipal CS policies within the NCSC databasei

(see figure 1).

Figure 1. Cit ies with CS policy by policy type

The NCSC database contains policies ranging from New York City with over eight

million residents, to Highland Park, Florida with only 230 people. Much attention has been given

to the largest cities, which provide leadership in CS policy development (Vega-Barachowitz et

al., 2013). However, municipalities with less than 100,000 residents are responsible for 74% of

all CS policies in the NCSC database. Large cities with greater resources are more likely to

develop design guidelines, while smaller cities are more likely to develop ‘policy.’ The

30 11 40

121

359

190

680

50

100

150

200

250

300

350

400

DesignManual

Execu/veOrder

InternalPolicy

Legisla/on Resolu/on Policy Plan

Num

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fCi/es

TypeofCSPolicy


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relationship between city size and their use of ‘resolutions’ and ‘legislation’ for CS policy is less

clear (see Figure 2).

The sample was stratified to capture differences across both city size and policy type.

Fifteen policies each of the policy types ‘policy’, ‘resolution’, and ‘legislation’ were randomly

sampled for cities with a population between 1,000 and 99,999 and for cities with a population

between 100,000 and 1,000,000. For the seven cities above 1,000,000 people, all policy types

were sampled for an additional 6 policies (excluding design guidelines). Finally, 17 design

manuals mostly representing large cities were sampled, resulting in a total sample of 113

policies. The total list of cities and policy types sampled is provided in Appendix A.

Figure 2. Distribution of CS Policy Type by City population

Analytical Approach


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Each policy was analyzed for specific policy content including:

• the legal status and strength of the policy;

• exceptions to its application;

• the stated definition of CS and the specific transportation modes listed beyond bicycles

and pedestrians;

• operational definitions, including language cues addressing the approach to

implementation in terms of actions, features, functions, process, or events to be

considered, developed, or carried out;

• inclusion of design considerations or directives; and

• direction for how to make trade-offs between types of users.

We coded language and concepts to represent the policies qualitatively. Further information on

this coding is presented in the findings.

3. Findings

Strength and Legal Status of Policies

The impact of CS policies is related in part to their legal status. Some policies are simply

a statement of support for CS principles, while others require legal conformance. This variation

in legal weight is reflected not only by the difference in policy types, but also in the different

organizational structures within municipal government. This review focused on the CS policies

alone, without accessing the context of the municipal governance that produced the policy. Thus

the analysis of the legal status of CS policy is limited to comparing across municipalities, not

within their individual context. Our analysis suggests however, that many CS policies are


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relatively weak. For example, according to the NCSC classification, non-binding ‘resolutions’

make up 43% of the total CS policies. For cities with a population under 200,000, only 13% of

policies legally binding ‘legislation’ (See figure 2). Many CS policies fall under the ‘policy’

category; this category was also quite ambiguous in terms of legal status, the resulting concern is

that a large number of CS policies may not legally challenge street building practices.

In this regard, small city resolutions appear to be stand-alone documents without mention

of further policy development, compared to those in large cities that often state an intent to create

additional CS policies such as design guidelines. For the ‘legislation” and ‘policy” types there is

more variation in directives for other policy development. These include integrating CS

principals with existing policy, as in the case of Hillsborough, NJ where the directive reads:

“municipal departments and professionals should review and either revise or develop

proposed revisions to all appropriate plans, development regulations, laws, procedures, and

rules including subsequent updates to the Township of Hillsborough Master Plan.”

Other variations include developing new non-motorized transportation network plans such as in

the CS ‘legislation’ in Williamston MI:

"City Council shall adopt a non-motorized transportation network plan. This plan shall be

approved by the Planning Commission, in consultation with, as appropriate, City Boards,

Commissions, and Staff."

Exemption provisions further complicate evaluating the strength of CS policy. NCSC

recommends that policies provide exemptions for “making a policy work in the real

world”(National Complete Streets Coalition, n.d.), and 62% of our policy sample do provide


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exemptions. The most common exemptions, found in 36 % of policies, are for facilities that

legally prohibit pedestrians and bicycles such as expressways. Another 18% of policies exclude

vehicles from pedestrian only streets. Forty-five percent of all policies provide exemptions for

excessive cost and/or lack of existing or future demand. ‘Excessive costs’ were typically defined

as more than 20% of the total project cost, with some municipalities having lower thresholds. For

example, in the case of Emerson, NJ and Fort Lee, NJ any project where the cost of providing

“pedestrian, public transit, and/ or bicycle facilities causes an increase in project cost in excess of

5%” would require additional approval by council prior to tendering the project. More typically,

jurisdictions look at cost and demand together. For example, Spokane, WA policy provides

exemption from providing for all users where “Cost of accommodation is excessively

disproportionate to the need or probable use, or is more than 20% of the project cost.” Other

jurisdictions allow exemptions based on demand. Dexter, MI’s policy, for example, notes,

“where there is no identified long-term need” as a justified exemption. Cost based exemptions

can imply that vehicle accommodation is the higher priority and accommodating other modes is

contingent.

NCSC is careful to recommend exemptions that do not create “loopholes,” yet

exemptions are inherently in tension with the aspirational idea of creating streets for all users.

Additionally, not providing facilities based on limited “need” can be self-fulfilling. This is

especially true in the context where pedestrians and cyclists do not already use the ROW because

they are unsafe environments lacking appropriate accommodations. A clear criterion for

providing exemptions has not been developed by NCSC or through policy development. Newark,

NJ, for instance, justifies exemptions to implementing CS based on “scarcity of population,

travel and attractors, both existing and future, indicate an absence of need for such


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accommodations” As Newark, NJ is fully urbanized, one must question what would in fact

constitute a “scarcity of population” exemption?

Definitions of Complete Streets in Municipal Policy

The academic literature and municipal policy are broadly consistent with the basic NSCS

definition that complete streets safely accommodate all types of road users regardless of travel

mode, age, or ability (NCSC, 2016). We analyzed both the stated definitions in our policy

sample, and the language used in the operational definition, i.e. the language that describes the

types of actions, features, functions, processes, or events necessary to create CS.

Stated Definition of Complete Streets

A full 80% of sampled policies provide a definition of complete streets. A typical

example reads:

“’Complete Streets’ are streets that are designed, built and operated to enable safe access for all users,

in that pedestrians, bicyclists, motorists and public transportation users of all ages and abilities are

able to safely move along and across the street right-of-way.” (Chattanooga, Tennessee, Chattanooga

City Code, Chapter 32, Article XIV Complete Streets)

Municipalities borrow language from other jurisdictions and from NCSC, with about one

third of the sample using very similar language to this. 72% mention safety, 62% refer to “all

users,” 46% mention “all ages,” and 47% mention “all abilities.” Some municipalities have very

condensed versions with, for example, Sioux Falls, South Dakota simply stating: “the term

‘Complete Streets’ is defined as streets that are designed to accommodate all potential users.”


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A few policies do not use the term ‘complete streets’ but still use language found in the

standard definition. Kansas, Missouri, for example uses “livable streets,” while La Crosse,

Wisconsin combines the concepts of CS with that of “green streets,” calling them “Green

Complete Streets”:

"Green Complete Streets are streets that safely accommodate all users of the right-of-way, including

pedestrians, people requiring mobility aids, bicyclists and drivers and passengers of transit vehicles,

trucks, automobiles and motorcycles, while at the same time incorporating best management practices

for addressing stormwater runoff." (La Crosse, WI, Ordinance No. 4627 §III, ¶ 5.18 (D))

CS literature also recognizes that public space and social activities do frequently occur within the

street ROW (Vega-Barachowitz, Koonce, & Flynn, 2013; Zavestoski & Agyeman, 2015b),

however, the definitions in the policy documents almost exclusively address the transportation

and movement function of the street, excluding more passive uses like sitting, meeting, or

talking.

In general, the approach to defining CS is abstract and raises questions including what it

mean to “enable safe access” for people of “all ages and abilities”? Does this emphasize safety

over other street functions such as movement? Are motor vehicles considered to be

‘accommodated’ even if motorized traffic operates at very highly levels of congestion and

reduced speeds? Are inexperienced cyclists safely accommodated in cycle lanes that may have

heavy, fast moving cycling traffic? At what age and abilities must very young (or very old)

pedestrians be able to safely use a street independently? What level of cognitive and physical

(dis)ability must be accommodated? Practitioners recognize many street designs as “complete”

that include very different levels of accommodation, and the provision that CS safely


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accommodate all users of all ages and abilities must be seen as aspirational; in practice this goal

is probably unattainable and design limits and trade-offs must be made.

Operational Definitions

While most policies offer some variation of the standard definition of CS, there are four

common approaches to defining CS in more operational terms in the literature: a design based

definition focusing on the physical features and elements of a street; a function based definition

focused on accommodating the needs of user groups; a process based definition focused on

incorporating CS concepts into street planning and design practices; and a context based

definition focused on the expected level of accommodation given the level of urbanization. The

four approaches highlight the lack of agreement on how to operationalize the concept of CS, but

also sheds some light on how municipalities weigh different aspects of CS in their policies.

The process and context based approaches are well articulated in the literature

(Kingsbury, Lowry, & Dixon, 2011; LaPlante & McCann, 2008; McCann, 2013; Winters et al.,

2016) and are often paired together. However, the physical design features and functional

requirements that constitute a CS in a given context are less defined (Vega-Barachowitz et al.,

2013; Winters et al., 2016). The design based approach focuses on debates surrounding the

necessary combination of street elements, typically related to pedestrian and cycling facilities,

needed to make a street complete. Design oriented definitions often list the typical CS elements

such as sidewalks, curb ramps, bike lanes, bus stops, etc.

The functional approach focuses on street performance considering both travel mode and

ability of the user. The function of the street is linked to its physical design; however also

incorporates performance considerations, such as safety, of the street environments not fully


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addressed by design alone. As reviewed above, the literature identifies difficulties with adapting

existing functional measurements such as level of service (LOS) to the multi-modal CS

environment (Elias, 2011; Sanders & Cooper, 2013). Many functional definitions are merely

reiterations of the basic CS definition that streets will safely accommodate all users.

The process based approach focuses on the institutional decision making process to

insure the inclusion and consideration of all user types throughout all phases of street planning

and development. McCann (2013) argues that transportation planning and engineering should

accommodate all users from the beginning stages of a project, not just plan for automobiles first,

then retrospectively accommodate pedestrians and other users as conflicts arise. Operational

definitions often use language that CS will be implemented through “designing, operating and

maintaining the transportation network,” however; institutional actors that would be held

responsible for these actions are not always identified.

The context based approach focuses on the expected level of provision for different

modes according to the intensity of urbanization (e.g. urban, suburban, or rural), the street’s

position in a conventional road classification system and the types of adjoining land uses. In this

regard, Kingsbury et al. (2011) assess the completeness of a street based on community

perceptions, expectations, and existing community amenities. Winters et al. (2016) found that

among transportation planning experts, the contextual considerations for defining CS included

“land-use, roadway typology, age and maturity of road, and the quality of roadway infrastructure

implemented with right-of way (ROW) upgrades.” (p. 2). In some cases, the context based

approach calls for minimal accommodation of non-motorized modes when demand is not

expected to be high.


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We classified the CS ‘resolutions’, ‘policy’, and ‘legislation’ documents using the four

approaches described above. CS policies use a broad range of language, and this exercise was

necessarily interpretive. Excluding design guideline policies, half of the policies use a function

definition, either alone (6%) or in combination with design (4%), context (1%), or process

definitions (40%) (Figure 3). Strikingly spare was the use of the context alone to define CS (1%).

Even combined with design, functional, and process approaches, context was only included in

13% of operational definitions in the sampled policy. While context is broadly discussed in the

CS literature and is sometimes discussed in other areas of the municipal policy, it is largely

absent from operational definitions.


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Figure 3. Approaches to defining complete streets within municipal CS ‘policy’,

‘ legislation’, and ‘resolution’ documents

Users, Modes and Trade-offs

CS are defined to accommodate all users regardless of mode, age, or ability, but almost

all sampled policies list the modes and users to be considered. These statements are considered

best practice by the NCSC but vary considerably. Four modes are at the core of CS policies with

93% listing bicyclists, 91% listing pedestrians, 87% listing transit vehicles and operators, and

76% listing motorists. Other modes and uses were mentioned in less than 50% of policies

including freight and commercial vehicles (35% of policies) and emergency vehicles (22% of

policies).

Many potential modes are not listed, for example skateboarders or electric bicycles are

typically not included. Some policies do note however that the modes listed are non-exclusive by


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using language like “including,” or “including but not limited to.” Palm Bay, Florida even

mentions “other non-traditional or evolving modes as may be appropriate.” Some specific

demographic groups are also listed, for example, children (27% of policies), the elderly (24% of

policies), and persons with disabilities (24% of policies), but generally users are defined by their

method of travel.

Few policies acknowledge potential conflicts between modes or user needs. Few

recognize the need for trade-offs between user accommodations. A small number, however, do

provide special consideration, or prioritization to certain modes. Both Emerson and

Hillsborough, New Jersey, for example, state that “special priority [should be] given to

pedestrian safety.” Likewise, La Crosse, Wisconsin, states that “freight shall be the priority” on

classified truck routes. The Village of Willow Springs, Illinois is exceptional in setting out a

hierarchy of accommodation “in the following order: pedestrians, bicyclists, transit users,

motorists and freight.” The vast majority of sampled policies, however, implicitly assume that it

is possible to adequately accommodate all modes and users on all streets except where prohibited

such as expressways.

The policies also do not address potential conflicts between modes and non-

transportation street functions. Few policies, for example, address place functions such as café

space and public space uses competing for space in public ROWs. Bicycle parking is often

mentioned, but not automobile parking. The movement of freight is mentioned, but not the need

for commercial goods delivery and servicing buildings which can create acute conflicts with

curbside bicycle facilities. Disabled users may be mentioned, but not their need for drop-off and

pick-up by motorized modes which, may create conflicts with cycle lanes.


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We expected that CS design guidelines when compared to the more general municipal

policy types would better address potential conflicts between users of the street. However, CS

definitions in the guidelines sampled are largely similar to those in the other policy types. Some

design policies however, did recognize and include concepts such as green streets, livable streets,

or sustainable streets. Tacoma, WA, for example, incorporates the urban design concepts of

‘livability’, ‘identity’ and ‘character’ in addition to ‘reducing environmental impacts’:

“Tacoma defines a Complete Street as a street that safely and comfortably accommodates all users

and travel modes, fosters livability, neighborhood identity and character and incorporates features that

reduce environmental impacts.”

Boston’s guidelines also go beyond a narrow transportation approach:

“The new Boston Complete Streets approach puts pedestrians, bicyclists and transit users on equal

footing with motor-vehicle drivers. The initiative aims to improve the quality of life in Boston by

creating streets that are both great public spaces and sustainable transportation networks. It embraces

innovation to address climate change and promote healthy living.”

Yet despite these more comprehensive definitions, design guidelines rarely acknowledge

potential conflicts between street users and functions. Indeed, diagrams of ROWs in sampled

guidelines tend to partition street space into ‘zones’, ‘realms’ or ‘components,’ with different

modes separately assigned to each (see figure 4). These representations and their corresponding

discussions simplify dynamic, complex interactions between modes and with other uses of the

street, they underplay conflicts between ‘zones’ or what should be sacrificed if there is not

sufficient space for all to be accommodated. As an exception, the Complete Streets Chicago

guidelines are noteworthy by articulating a clear hierarchy, prioritizing pedestrians first, then


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transit, followed by bicyclists, then automobiles. The Guidelines also provide example designs of

priority streets for pedestrians, transit, and bicyclists that begin to address the user trade-offs.

Figure 4. Example of “Components” of a Complete Street from Philadelphia (p.

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Network and Context

The CS literature suggests that network and context considerations should be key

components of complete streets policy and development (Kingsbury et al., 2011; LaPlante &

McCann, 2008; Winters et al., 2016). Only 21% of the policy sample explicitly mention network

or context, most only briefly. Rochester, New York, for example, “seeks to create an

interconnected network of transportation facilities which accommodate all modes of travel in a

manner that is consistent with neighborhood context and supportive of community goals.”


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Likewise, the Flint, Michigan’s definition of CS states they are “an inclusive context sensitive

design framework and infrastructure.”

The CS policy of Sioux Falls, South Dakota, is one of the few giving more detailed

guidance on network and context issues. For example, the policy prioritizes CS improvements

around schools and parks, in areas with non-motorized demand. Similarly, North Hempstead,

New York refers to the existing street “functional classification standards, traffic volume, and

accident history” as context factors for the “practical” implementation of CS. Exemptions within

policy also acknowledge context considerations by exempting streets where there is no “need,”

or where need does not justify costs. About 10% of policies also note transit facilities are not

needed where there are no transit routes. Only Little Rock Arkansas, however, acknowledges

network considerations by noting that streets can be exempt “where an equivalent project along

the same corridor is already programmed to provide the needed infrastructure or facilities.”

We expected design guidelines by definition, to more directly address and define the

design considerations for specific contexts. They do so however, only to varying degrees. For

example, Louisville, Kentucky’s guidelines mention downtown, suburban, and rural street

contexts, and Fort Lauderdale’s loosely links functional road classification to street typologies

based on typical urban and suburban contexts. In general, however, the relationship between CS

design and the functional road classification is not defined. Further, most guidelines primarily

address the most densely urbanized areas and urban street conditions giving little guidance for

more suburban and rural conditions. For example, Tacoma, Washington’s guidelines address

only ‘mixed-use centers’, completely ignoring the context of more residential neighborhoods.

Though downtown or urban streets may be more complex than those in suburban and rural

contexts, the latter are common and need different design guidance. As noted above, larger


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municipalities are more likely to develop design guidelines, but suburban and especially rural

municipalities with fewer resources have few models. General guides such as NACTO’s Urban

Street Guide are helpful, but also tend to have a very urban focus.

In general, there appears to be no clear consensus of how to define and incorporate

network and contextual considerations into CS policies. Most policies direct that street projects,

whether of new streets or for street rebuilding or re-striping should be done using CS principles.

Over time, is seems to be assumed, individual projects will accumulate to form a network of CS.

In this respect, complete streets transformation will likely be driven by the need for extending

and repairing the motor-vehicle network rather than the need for non-motor vehicle

accommodation. More network and context thinking may be incorporated into pedestrian and

bicycle plans, but most CS policies are directed at individual street projects with little context or

network considerations.

4. Discussion and Conclusions

The concept of CS represents a profound shift in orientation from streets designed and

planned to primarily serve automobiles toward streets that safely accommodate all types of users,

including non-motorized users. This policy review is not intended to minimize this important

achievement, but rather to help in understanding the logic of CS policies so they can be

strengthened. Our analysis finds that many CS policies are more reflective of a general cultural

change in street design and a desire to consider non-motorized users than in creating clear legal

authority that requires CS implementation or creates concrete directions for this change. Many

policies are produced by small jurisdictions that have limited resources to create change and

most are ‘resolutions’ that offer support to the concept of CS but do not create requirements or


23

processes to implement change. These types of weak policies may be implemented in some

places, but do not create a solid foundation for transforming deeply institutionalized auto-

oriented street building practices.

Formal CS definitions articulate the goal of safely accommodating all users of all

abilities. In terms of more operational definitions, most policies use a functional approach that

does not go much beyond the formal definition. While safely accommodating all users is an

important, easily understood aspiration, it has some limitations. First, while the scholarly

literature and some CS design guidelines introduce concepts such as ‘walkability’ and

‘livability,’ at its heart the concept of CS is a transportation concept. We found municipal

policies do not recognize the role of the street as a public space. Several design guidelines,

including Chicago Complete Streets, do vaguely describe amenity zones that may provide

seating and other facilities, but how to make trade-offs between streets as transportation facilities

and streets as public space is not articulated in the policy documents.

Within the transportation function, CS policies give little direction for how to make

necessary trade-offs between users and what qualifies as sufficient accommodation. Public street

ROWs are finite spaces and, even where they are wide enough to accept a “facility for

everyone,” the size makes it a challenging environment for active modes. Further, even high

quality active-transportation facilities will not be safe and accessible for some users. Yet, very

few reviewed policies state that some modes such as pedestrians or cyclists should be prioritized

or that there should be a hierarchy of accommodation. In general, policies are more explicit

about exceptions for when pedestrians and bicyclists do not need to be accommodated, than they

are in how to make difficult trade-offs. CS policies should better acknowledge the need for trade-

offs and give guidance for how to make these decisions.


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Operational definitions suggest that CS principles should be incorporated into the design,

construction, maintenance, and operation of municipal streets. A few even assign explicit

institutional responsibility for this process. Some policies list the responsibility with the city

manager and/or city council, others named engineering or public works departments, though

others were undefined or vague including ‘all relevant departments’ or simply the ‘city’. Policies

can help guide decision making so it is not ad hoc or politically based when conflicts arise. Many

municipalities do point to regional, state, and federal policy as well as AASHTO, NACTO, and

HCM guides. Each of these different approaches have different outcomes on how trade-off

decisions will be made in the street ROW. Without clear priorities, conventional auto-based

design solutions may simply be replicated. While it should not be expected that broad policy is

able to solve the complex process of designing physical streets, clearer guiding principles of how

to make trade-offs and the priority of accommodation are important. Lack of guidance on how to

incorporate context and network issues further inscribe some of these issues, as trade-offs will

likely be different in different contexts and depending on a corridor or link’s role in a greater

network. Treating every street project as if it needs to meet the same definition of completeness

will tend to confine complete street improvements to the project level which is dominated by the

needs of moving motor-vehicles.

There is no doubt that the concept of CS both represents a cultural change in street design

and has been key to promoting streets that better accommodate sustainable non-motorized modes

specifically, pedestrians and cyclists. The policies and associated guidelines, standards, and other

design documents that guide the development of CS are also evolving rapidly. Some of the issues

we have identified may be being resolved as part of this process. If history is a guide, however,

new standards and guidelines are likely to be highly institutionalized and it is important to get the


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fundamentals correct from the beginning. In our view, some key conceptual issues in CS

policies, especially the implicit assumption that all streets can adequately safely accommodate all

users without trade-offs, may hinder the development of even better streets, and without better

guidance for how to make these trade-offs, old institutional frameworks may continue to create

streets that, foremost, accommodate motor vehicles. The concept of CS has been of enormous

importance in re-conceptualizing street design models. Examining and improving some of their

base assumptions can help make them even stronger.

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AppendixA:

CompleteStreetMunicipalPolicySample,providedfromNCSC’spolicydatabase.

Municipality State Policy NCSC Type Year Population

LargeCitySample(>1,000,000<=100,000)Legislation >1,000,000<=100,000

Chattanooga TN City Code II Ch. 32, Art. XIV leg 2014 167,674

Rochester NY Ordinance No. 2011-356 leg 2011 210,565

Toledo OH Toledo Municipal Code, Chapter 901 leg 2012 287,208

Columbia MO Model Street Standards leg 2004 108,500

Seattle WA Ordinance No. 122386 leg 2007 608,660

Albuquerque NM O-14-32 leg 2015 545,852

Spokane WA Ordinance leg 2011 208,916

Cleveland OH Ordinance No. 798-11 leg 2011 396,815

Kansas City MO Resolution No. 110069 leg 2011 459,787

Columbus OH Ordinance 1987-2008 leg 2008 787,033

Little Rock AR Ordinance leg 2015 193,524

Indianapolis IN Chapter 431, Article VIII leg 2012 820,445

Stamford CT Chapter 231, Article XII leg 2015 122,643

St. Louis MO Ordinance No.69955 leg 2014 319,294

Oakland CA Ordinance No. 13153 leg 2013 390,724

SmallCitySample(>100,000<=1,000)Legislation

>100,000<=1,000

Burien WA Ordinance No. 599 leg 2011 33,313

Troy NY City Code Chapter 271 - Complete S leg 2014 50,129

Ocean Shores WA Ordinance No. 916 leg 2012 5,569

La Crosse WI Ordinance No. 4627 leg 2011 51,320

Williamston MI Ordinance No. 325 leg 2011 3,854

Pevely MO Ordinance No. 1238 leg 2010 5,484

Issaquah WA Issaquah Municipal Code Chapter 12 leg 2007 30,434

Ypsilanti MI Ordinance leg 2011 19,435

South Shore KY Ordinance 316-2012 leg 2012 1,122

Holyoke MA Section 78-58--Complete Streets leg 2014 39,880

Saline MI Ordinance No. 731 leg 2010 8,810

Dexter MI Ordinance No. 2010-05 leg 2010 4,067

Delhi Township MI Ordinance 123 leg 2012 25,877

Redmond WA Redmond Municipal Code Chapter 1 leg 2007 54,144

Clayton MO Bill No. 6294 leg 2012 15,939

LargeCitySample(>1,000,000<=100,000)Policy >1,000,000<=100,000

Palm Bay FL Resolution No. 2011-22 pol 2011 103,190

Cedar Rapids IA Resolution 1004-07-14 pol 2014 126,326

Baton Rouge LA Resolution 51196 pol 2014 229,423

Richmond VA Resolution No. 2014-R172-170 pol 2014 204,214

Hayward CA Complete Streets Policy pol 2013 144,186

Savannah GA Complete Streets Policy pol 2015 136,286

Elizabeth NJ Resolution of the Municipal Council o pol 2014 124,969

North Hempstead NY Complete Streets Policy Guide pol 2011 226,322

Billings MT Resolution pol 2011 104,170

Fort Lauderdale FL Complete Streets Policy pol 2013 165,521

St. Petersburg FL Administrative Policy #020400 pol 2015 244,769

Rochester MN Complete Streets Policy pol 2009 106,769

Springfield MO Complete Streets Policy pol 2014 159,498

Berkeley CA Resolution 65,978-N.S. pol 2012 112,580

Oakland CA Complete Streets Policy pol 2013 390,724

Orlando FL Complete Streets GMP Amendment pol 2015 238,300

SmallCitySample(>100,000<=1,000)Policy

>100,000<=1,000

Hillsborough NJ Resolution to Adopt and Establish pol 2014 38,303

Great Neck Plaza NY Complete Streets Policy Guide pol 2012 6,707

New Hope MN Complete Streets Policy pol 2011 20,339

Charlottesville VA Complete Streets Policy pol 2014 43,475

Weymouth MA Complete Streets Policy pol 2015 53,743

Baldwin Park CA Resolution No. 2011-028 pol 2011 75,390

Riverside OH Resolution No. 14-R-1918 pol 2014 25,201

Elizabethtown PA Resolution No. 2014-12 pol 2014 11,545

Chicago Heights IL Resolution No. 2013-43 pol 2013 30,276

Zeeland MI Complete Streets Policy pol 2013 5,504

Sandpoint ID Resolution pol 2010 7,365

Hudson MA Complete Streets Policy pol 2015 19,063

Independence MN Complete Streets Policy pol 2011 3,504

Egremont MA Complete Streets Policy pol 2016 1,225

LargeCitySample(>1,000,000<=100,000)Resolution

>1,000,000<=100,000

Kansas City KS Resolution res 2011 145,786

Warren MI Resolution res 2012 134,056

Newark NJ Resolution res 2012 277,140

Jersey City NJ Resolution No. 11-317 res 2011 247,597

Birmingham AL Complete Streets Resolution res 2011 212,237

Providence RI Resolution res 2012 178,042

St. Paul MN Resolution No. 09-213 res 2009 205,068

Overland Park KS Resolution No. 3919 res 2012 173,372

Flint MI Resolution No. _ res 2009 102,434

Columbus GA Resolution 92-14 res 2014 189,885

Sioux Falls SD Resolution No. 53-15 res 2015 153,888

Fremont CA Resolution No. 2013-32 res 2013 214,089

New Haven CT Complete Streets Order res 2008 129,779

Everett WA Resolution res 2008 103,019

Mobile AL Resolution 60-247-2011 res 2011 195,111

SmallCitySample(>100,000<=1,000)Resolution

>100,000<=1,000

Danville CA Resolution No. 5-2013 res 2013 42,039

Ewing Township NJ Resolution 14R-170 res 2014 35,790

Escanaba MI Resolution res 2011 12,616

Dubuque IA Resolution No. 124-11 res 2011 57,637

Acme Township MI Resolution res 2011 4,375

Emerson NJ Resolution res 2010 7,401

Fort Lee, Borough of NJ Resolution CN-6 res 2012 35,345

Lawton OK Resolution res 2011 96,867

Woolwich NJ Resolution R-2013-148 res 2013 10,200

Bonita Springs FL Resolution res 2014 43,914

Brookhaven NY Resolution 2010-993 res 2010 3,451

Sault Ste. Marie MI Resolution res 2010 14,144 Rutherford, Borough of NJ Resolution res 2011 18,061

Titusville FL Resolution No. 15-2011 res 2011 43,761

Northvale NJ Resolution 2013-17 res 2013 4,640

CitiesOverOneMillionAllPolicyTypes(1,000,000+) 1,000,000+Phoenix AZ Ordinance G-5937 ord 2014 Phoenix AZ Ordinance S-41094 ord 2014 Houston TX Executive Order exec 2013 San Antonio TX Policy pol 2011 Philadelphia PA Executive Order exec 2009 Philadelphia PA Bill No. 120532 ord 2012 CitiesOverOneMillion(1,000,000+)DesignGuidelines 1,000,000+New York NY Street Design Manual des 2009 New York NY Sustainable Streets des 2008 Chicago IL Complete Streets Chicago des 2013

Philadelphia PA Philadelphia Complete Streets Design Handbook des

LargeCitySample(>1,000,000<=100,000)DesignGuidelines

>1,000,000<=100,000

Sacramento CA Sacramento Pedestrian Friendly Streets des 2004 466,488

Tacoma WA Complete Street Guidelines des 2009 198,397

Boston, MA MA Complete Streets Guidelines des 2013 617,594

Fort Lauderdale FL Complete Streets Manual des 2013 165,521

Louisville KY Complete Streets Manual des 2007 597,337

Charlotte NC Urban Street Design Guidelines des 2007 731,424

Wichita KS Multimodal Accommodation Policy a des 2014 382,368

New Haven CT Complete Streets Design Manual des 2010 129,779

SmallCitySample(>100,000<=1,000)DesignGuidelines

>100,000<=1,000

Everett MA Complete Streets Guide: A Healthy A des 2012 41,667

Davidson NC Town of Davidson Planning Ordinance des 2012 1,094

San Mateo CA Design Guidelines des 2015 97,207

Basalt CO Complete Street Design des 2005 3,857

Deerfield Beach FL Complete Streets Guidelines des 2013 75,018

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