T4A comments on Model Minimum Uniform Crash Criteria (MMUCC) Guidelines

On May 3, Transportation for America, a program of SGA, submitted comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for improvements to the Model Minimum Uniform Crash Criteria (MMUCC) Guidelines. The MMUCC guidelines provide recommendations to state and local agencies on the collection of crash data, specifically looking at the variables that are required to be collected. Standardized, timely, and comprehensive crash data are important now more than ever as the U.S. confronts a historic rise in traffic violence. However, the current proposed revisions to the MMUCC fall short of what is needed to make our streets safer for people of all ages and abilities, whether walking, biking, or using assistive devices like wheelchairs or walkers.


Transportation for America joined other partner organizations including the League of American Bicyclists and Salud America in submitting comments to address concerns with the proposed MMUCC, especially around the need to better incorporate principles of a Safe System Approach and accurately capture the systemic causes of crashes. Additionally, the proposed MMUCC has guidelines that do not treat all road users equitably and continue to blame people for crashes instead of reflecting on the needed design and operational changes to the transportation system in order to avoid death and serious injuries when crashes occur.  Across the U.S., people walking and rolling are bearing a disproportionate burden of the nation’s transportation safety crisis. We need our crash data to support and not undermine efforts to address this. 

In reviewing the proposed MMUCC, SGA and partner organizations specifically called for addressing: 

As NHTSA reevaluates the MMUCC 6th edition draft, it will be crucial to reflect on the core purpose of our transportation system, which is to move all people, regardless of ability, without barriers within our communities. NHTSA will have to peel back historical context within their guidance and standards-setting framework that has seen the automobile as the primary mode of transportation and human behavior (especially for those outside the vehicle) at fault for crashes and not street design.


Advocacy Complete Streets