Illinois Complaint Against The Illinois Department of Transportation

Return Date: No return date scheduled
Hearing Date: 9/5/2019 10:00 AM - 10:00 AM

Courtroom Number: 2601
Location: District 1 Court FILED
Cook County, IL 5/6/2019 12:00 AM
DOROTHY BROWN
CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
2019CH05641
4933224
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION
R. CLIFFORD POTTER )
)
Plaintiff, )
) 2019CH05641
v. ) No. ____CH_____
)
OMER OSMAN, in His Official Capacity )
As Acting Secretary, and Any Successor )
Secretary of the Illinois Department )
of Transportation, and the ILLINOIS )
DEPARTMENT OF TRANSPORTATION)
)
Defendants. )
VERIFIED COMPLAINT FOR COMMON LAW

WRIT OF CERTIORARI, DECLARATORY
JUDGMENT AND INJUNCTIVE RELIEF
Contents
THE PARTIES ....................................................................................................................... 4
JURISDICTION AND VENUE ................................................................................................ 4
NATURE OF THIS CASE ....................................................................................................... 5
FACTS COMMON TO ALL COUNTS ...................................................................................... 7
A. Part of WRUD May Seem Like A Country Road ............................................................ 7
B. WRUD Was To Be Improved Years Ago Because It Is An SRA ................................... 10
C. Nearby Communities Have 30 MPH Speed Limits on Better Highways...................... 11
D. IDOT’s 40 MPH Speed Limit Is Much More Dangerous Than 30 MPH ..................... 14
E. IDOT Allows WRUD speeding ...................................................................................... 15
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F. Speeding Is Worst Between Maple and Walters............................................................17
G. NBJH Did Not Get A School Speed Zone Due To Fictitious “Funnels” ........................17
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
H. IDOT Is Satisfied With Little To No Northbrook Police Enforcement ....................... 18

I. Removal Of Parking Made WRUD Less Safe For Pedestrians ...................................... 19
J. Stanchions At Shermer And Waukegan Made WRUD Less Safe ................................. 19
K. The Lights At Walters Avenue And Voltz Road Increased Speeding ........................... 20
L. Flat Parkways Were Approved Near Schools Despite Known Dangers ....................... 21
M. IDOT Has Kept WRUD In Its 1996 Condition Despite Available Funds .................... 22
N. IDOT Has Made WRUD Far Less Livable .................................................................... 23
O. WRUD’s Composition Makes Speeding More Dangerous ........................................... 24
P. Trucks On WRUD Make It More Dangerous................................................................ 25
Q. IDOT’s Speed Policy Endangers Plaintiff And Others ................................................. 26
R. The 85th Percentile and Related Rules Should Not Apply To WRUD.......................... 29
S. IDOT Uses Different Standards For WRUD Than For Its Neighbors .......................... 31
T. Plaintiff’s Fruitless Efforts Before Filing This Complaint ............................................ 33
U. IDOT’s Failure To Implement Traffic Calming Measures ........................................... 34
V. A Road Diet With 25 and 30 MPH Speed Limits Is Required ..................................... 35
COUNT I Violation of 625 ILCS 5/11-601 and 5/11-602 WRIT OF CERTIORARI
ENJOINING IDOT FROM USING SPEED LIMITS OVER 30 MPH IN URBAN DISTRICTS
........................................................................................................................................... 37
PRAYER FOR RELIEF ..................................................................................................... 39
COUNT II Violation of 625 ILCS 5/11-601 and 5/11-602 WRIT OF CERTIORARI
ENJOINING IDOT FROM ALL NON-STATUTORY LIMITATIONS TO URBAN DISTRICTS39
COUNT III Violation of 625 ILCS 5/11-601 and 5/11-602 WRIT OF CERTIORARI
REQUIRING IDOT TO CLASSIFY WRUD AS AN URBAN DISTRICT .............................. 43
COUNT IV Violations of 625 ILCS 5/11-601 and 11-602 WRIT OF CERTIORARI
ENJOINING IDOT FROM PERMITTING ILLINOIS VEHICLE CODE VIOLATIONS AND
REQUIRING IDOT TO ENFORCE SPEED LIMITS ON WRUD .......................................... 44
COUNT V Violations of 625 ILCS 5/11-208.1 WRIT OF CERTIORARI ENJOINING
VIOLATION OF THE ILLINOIS VEHICLE CODE AND REQUIRING IDOT TO USE A 30
MPH AND LOWER SPEED LIMIT ON WRUD ................................................................. 45
002
COUNT VI Violation of 14th Amendment’s Equal Protection Clause Under
the US Constitution WRIT OF CERTIORARI ENJOINING IDOT FROM VIOLATING
THE EQUAL PROTECTION CLAUSE OF THE US CONSTITUTION REGARDING WRUD .. 47
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
PRAYER FOR RELIEF ...................................................................................................... 47

COUNT VII Violation of Equal Protection Under the Illinois Constitution
WRIT OF CERTIORARI ENJOINING IDOT FROM VIOLATING THE EQUAL PROTECTION
CLAUSE OF THE ILLINOIS CONSTITUTION REGARDING WRUD .................................... 48
COUNT VIII Violation of 625 ILCS 5/11-602 WRIT OF CERTIORARI REQUIRING
IDOT TO APPLY A ROAD DIET TO WRUD ................................................................... 49
COUNT IX 735 ILCS 5/2-701, ET SEQ. DECLARATORY JUDGMENT FINDING THAT AN
INJUNCTION IS APPROPRIATE TO STOP IDOT’S ULTRA VIRES ACTIONS REGARDING
WRUD .............................................................................................................................. 52
Verification ................................................................................................................. 53
EXHIBIT 1 IDOT SPEED POLICY .................................................................................. 54
GROUP EXHIBIT 2 REPRESENTATIVE GABEL IDOT CORRESPONDENCE ............71
EXHIBIT 3 WRUD SRA REPORT (EXCERPT)............................................................... 75
GROUP EXHIBIT 4 NORTHBROOK SPOT SPEED STUDIES AND SPEEDING
TICKETS ............................................................................................................................ 93
GROUP EXHIBIT 5 IDOT LETTERS TO NORTHBROOK REGARDING SPEED
LIMITS ............................................................................................................................. 121
EXHIBIT 6 US DOT NHTSA BICYCLIST AND PEDESTRIAN SAFETY ...................... 154
EXHIBIT 7 WHY AMERICAN TRUCKS ARE SO DEADLY FOR PEDESTRIANS AND
CYCLISTS .........................................................................................................................157
EXHIBIT 8 SPEED LIMITS LEADING TO CHANGE................................................... 163
EXHIBIT 9 SPEED LIMIT REDUCTIONS .................................................................... 170
EXHIBIT 10 ILLINOIS STRATEGIC HIGHWAY SAFETY PLAN 2017 - OBJECTIVES
AND STRATEGIES TO ADDRESS PEDESTRIAN CRASHES……………………………….…181
003
Hearing Date: 9/5/2019 10:00 AM - 10:00 AM
Courtroom Number: 2601
Location: District 1 Court
Cook County, IL

COUNTY DEPARTMENT, CHANCERY DIVISION FILED
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
5/6/2019 12:00 AM
DOROTHY BROWN
R. CLIFFORD POTTER ) CIRCUIT CLERK
COOK COUNTY, IL
) 2019CH05641
Plaintiff, )
) 2019CH05641
v. ) No. ____CH_____
)
)
Defendants. )

For his Complaint against Defendant Omer Osman, in his official capacity as
Acting Secretary of the Illinois Department of Transportation (“IDOT”), and IDOT,
Plaintiff R. Clifford Potter states as follows.
THE PARTIES
1. Plaintiff lives on Waukegan Road (Illinois Highway 43) in downtown Northbrook,
Illinois.
2. Defendant IDOT is the State of Illinois agency in charge of all state highways.
3. Defendant Omer Osman directs the activities of IDOT.
4. All references to IDOT below include Defendant Osman who can order IDOT to do
what he deems appropriate.
JURISDICTION AND VENUE
5. This action involves Illinois Highways 43 (Waukegan Road) from Dundee Road to
Voltz Road (“Waukegan Road Urban District” or “WRUD”) in Northbrook.
004
6. The individual parties are residents of Illinois and IDOT is a State of Illinois agency
subject to the jurisdiction of this Court for (1) common law writs of certiorari because
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defendants have acted ultra vires in contravention of 625 ILCS 5/1-214, 5/11-601, 5/11-
602, 625 ILCS 11-208.1, and the equal protection clauses of the United States and Illinois
Constitutions and (2) the Declaratory Judgment Act, 735 ILCS 5/2-701 et seq.
7. Venue is proper under 735 ILCS 5/2-101 and 735 ILCS 5/2-103 because events
giving rise to the claims below occurred in Cook County.
NATURE OF THIS CASE
8. This case involves IDOT’s actions regarding Waukegan Road in Northbrook from
Dundee Road to Voltz Road, called the Waukegan Road Urban District (“WRUD”) in the
Complaint.
9. IDOT has used versions of its Policy on Establishing and Posting Speed Limits on
the State Highway System (Plaintiff’s Exhibit 1 is the 2014 Policy, hereafter “Speed
Policy”) to set WRUD’s speed limit over the past seventeen or more years and according
to IDOT’s Chief Counsel on February 1, 2019, still uses it without change despite the fact
that most of the versions previously on IDOT’s website have been removed.
10. On January 1, 2014, the Illinois Vehicle Code (“IVC”) was amended to change
certain speed limits and to require the imposition of mandatory speed limits including 30
MPH speed limits in Urban Districts.
11. In ultra vires violation of 625 ILCS 5/11-601 and 11-602 of the Illinois Vehicle Code,
the 2014 Speed Policy was amended to ignore the 30 MPH mandatory speed limit
allowing IDOT personnel to set higher speed limits for Urban Districts up to 55 MPH.
12. IDOT has determined that WRUD is not an Urban District, using ultra vires
restrictions in the Speed Policy to limit Urban Districts in Northbrook and elsewhere.
005
13. The Speed Policy also allows IDOT to discriminate in an ultra vires manner with
respect to those traveling and living on, near and through WRUD.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
14. IDOT has set the speed limit for WRUD at 40 MPH in and near downtown
Northbrook.
15. Thus, IDOT has insisted that, unlike the 25 and 30 MPH speed limits used by IDOT
on safer highways in neighboring municipalities, Plaintiff must face much greater danger
of more serious injury and death.
16. Plaintiff lives on a much less livable highway than those in neighboring
municipalities even at 25 and 30 MPH.
17. Even if there were no Urban District in Northbrook, the 25 and 30 MPH speed
limits used on safer parts of Waukegan Road and other highways than WRUD must be
used on WRUD as a matter of law. Otherwise, as now, illegal discrimination is occurring
including the statutory requirement of equal treatment under the Illinois Vehicle Code.
18. IDOT allows speeding by up to 90% of all who drive on WRUD up to in excess of
80 MPH, in ultra vires disregard of the speed limits.
19. The only practical way to obtain compliance with the speed limit on WRUD is
through a lower speed limit and a road diet, reducing the lanes on WRUD to three, with a
center turn lane.
20. Pursuant to Illinois law, the new configuration requires the creation of bicycle
lanes and parkways that were promised in 1996 but never provided while federal and state
money was spent nearby on roads that include 30 MPH speed limits. All could and should
be done at far less cost to IDOT and Plaintiff.
21. Plaintiff has exhausted all options other than seeking a remedy from this Court.
006
22. This lawsuit is the only means available to challenge IDOT’s unlawful, ultra vires
actions.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
23. This Complaint will benefit all Urban Districts and all others throughout the State
of Illinois who face IDOT’s discriminatory “Speed Policy,” requiring that IDOT comply
with Illinois and federal law.
FACTS COMMON TO ALL COUNTS
24. Since 2002, IDOT has repeatedly refused to lower the 40 MPH WRUD speed limit
despite multiple requests from the Village of Northbrook for IDOT to protect its residents.
25. In 2017, IDOT refused School District 28’s request to assign it a school speed zone
for Northbrook Junior High School based on largely fictitious findings, leaving as much
as 90% of the traffic going by at speeds up to over 80 MPH.
26. Despite repeated requests by Plaintiff and others, IDOT has refused to implement
necessary improvements on WRUD.
27. Unique among all of the surrounding municipalities, IDOT has refused to provide
Northbrook and its schools with the far safer speed limits enjoyed by their neighbors, even
when State Representative Gabel requested IDOT to do so.
A. PART OF WRUD MAY SEEM LIKE A COUNTRY ROAD
28. IDOT has several important benchmarks regarding speed limits that any good
engineering and traffic study would employ. Some of these are on the sign below.
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(Front page, Speed Concepts: Informational Guide (USDOT, Federal Highway

Administration September 2009)
29. IDOT has repeatedly stated to Northbrook that it is only interested in drivers’
inferred speed. The “right” speed to which IDOT has subjected Plaintiff is the speed at
which 85% of the drivers on WRUD choose to drive, irrespective of the safety of Plaintiff,
his children and all others who live by and use WRUD. Pedestrians and bicyclists are
ignored under this approach, as are WRUD design flaws and inherent dangers including
those IDOT says should be modified and improved.
30. WRUD is marked in blue below. It is in the center of Northbrook, including a small
part of what has been officially designated as downtown. After discussion with
Northbrook, Representative Gabel called all of WRUD “downtown Northbrook” with a
copy to Village President Frum. (October 9, 2014 Letter of Representative Gabel to IDOT
(Group Exhibit 2))
008
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
31. The design, sightlines, and implementation of WRUD south of Plaintiff’s house
make it seem as if it were a country road built for high speeds. Thus, for most driving on
that portion of WRUD, a speed limit exceeding the posted speed limit makes sense. At
one time, IDOT had marked WRUD for a 45 MPH speed limit based on the Speed Policy.
That higher speed limit has been threatened but never implemented.
32. Interspersed after the street in the picture above are residences and streets, many
hidden from view before drivers get close even in the winter months.
33. Instead of the typical country road WRUD seems to be south of Plaintiff house,
WRUD has vehicle and pedestrian traffic for three nearby schools, numerous streets and
driveways and a junior high school right next to the roadway.
009
B. WRUD WAS TO BE IMPROVED YEARS AGO BECAUSE IT IS AN SRA
34. IDOT has refused to implement the least expensive changes to WRUD that would
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increase safety. It has refused to lower the speed limit despite 30 MPH speed limits in
nearby municipalities including on Waukegan Road itself. The expense in doing so would
be the low cost of replacing speed limit signs. IDOT has also refused to post signs warning
drivers of the dangers on WRUD, including hidden driveways and urban streets.
35. IDOT has also refused to implement the changes it said would be done by 2010.
Thus, WRUD became part of a Strategic Regional Arterial (“SRA”) created in 1996 to
funnel traffic into Chicago on municipal streets rather than on expressways.
36. IDOT has added traffic to WRUD, forcing more heavy-duty trucks and semi-trailer
trucks into this four-lane undivided unlimited access highway.
37. Pedestrians and bicycles right next to vehicles traveling well over 40 MPH is
clearly a danger.
38. However, according to IDOT in 1996, WRUD would be vastly improved with new
and better parkways, new sidewalks, and roadway improvements including a raised
median.
39. Twenty-three years later, almost all of the improvements have not been
implemented. (IDOT SRA Planning Study, Illinois Route 43, Chapter 4: Corridor Analysis
by Segment (April 1996) (excerpt) (Exhibit 3))
40. The improvements were “consistent with SRA policy [and were] developed by
evaluating numerous factors including the year 2010 projected travel demand, the
existing roadway characteristics, and the character of development along the route.”
010
41. Apart from the turn lane at Maple, no plans exist for any other improvements,
keeping WRUD much less safe and far more unlivable than any other part of Waukegan
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Road and other nearby Illinois highways.
42. WRUD is far more dangerous for pedestrians and bikers than any neighboring
state highway even ignoring the speeds involved.
43. Many if not most of WRUD sidewalks are at highway level without curbs.
44. WRUD remains an undivided unlimited access SRA with around 200 “access
points” from which traffic enters and exits the roadway.
C. NEARBY COMMUNITIES HAVE 30 MPH SPEED LIMITS ON BETTER HIGHWAYS
45. Instead of a highway that integrates into the community, helping over 1,200 school
age pedestrians and bicyclists go to three schools, IDOT has opposed any improvements
and has no plans to implement those that would make WRUD far more livable and safer.
46. No neighboring highway is as unsafe or as unlivable as WRUD.
47. None has as many residential driveways and streets, each presenting its own
danger to both residents and those traveling on WRUD alike.
48. IDOT has insisted on a 40 MPH speed limit and allowed much higher speeds on
WRUD over at least the past seventeen years, leaving Plaintiff, his and others’ children,
seniors, the disabled, bicyclists, and others far less protected than those in nearby
municipalities with far better and less dangerous highways and far lower vehicle speeds.
49. On roads like WRUD, thirty MPH and lower speed limits are crucial to the safety,
livability, and better health for children and adults in towns and cities.
50. On information and belief, WRUD is the only segment of any nearby state highway
with 200 access points and as many residential driveways as are on WRUD.
011
51. On information and belief, WRUD is the only nearby state highway with abutting
residential and business properties, including properties downtown, that has a 40 MPH
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
speed limit.
52. On information and belief, WRUD may be the only undivided highway in the State
with vehicles driving at up to over 80 MPH in and near a downtown.
53. On information and belief, WRUD is the only highway segment with so few
improvements called for in a Final SRA Report for any Illinois highway.
54. On information and belief, other nearby SRAs and National Highways, including
Waukegan Road and Dundee Road in Northbrook, have been steadily improved. IDOT
and Northbrook have regularly improved Dundee Road, Pfingsten, and lower Waukegan
Road in Northbrook since 1996.
55. Nearby SRAs and National Highways have been assigned substantially lower
speed limits than WRUD.
56. Waukegan Road in Glenview and Deerfield and Willow Road in Northfield,
Northbrook’s neighboring municipalities, have 30 MPH speed limits on more modern,
much safer stretches of state highways.
Waukegan Road, Downtown Glenview - Parking lanes on both sides protecting
pedestrians:
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Willow Road, Northfield near Waukegan Road - Median, raised sidewalks, and
parkways on both sides protecting pedestrians:

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Waukegan Road north of Lake-Cook Road, Deerfield – Parkway, drain system, and
sidewalk protecting pedestrians with one access point in sight.
Waukegan Road north of Deerfield Road, Deerfield – Two access points with no
residential driveways in sight.
57. During his meeting with certain IDOT personnel, when asked about this
unfairness regarding Deerfield, an IDOT employee present said he could figure out why
013
there was a difference. No further discussion about these differences has ever occurred
despite repeated opportunities to do so.

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
58. Unlike its neighboring highways, many WRUD sidewalks are level with the
roadway.
59. New sidewalks, turn lanes, new pedestrian crossings, and street widening to
accommodate double turn lanes were identified by IDOT in 1996. All would have made
WRUD safer.
60. Instead of these improvements, IDOT has turned WRUD into an ever-more
dangerous, out-of-date highway, with far more deadly speed, speeding, noise and
particulate pollution than faced by Plaintiffs’ Waukegan Road neighbors.
D. IDOT’S 40 MPH SPEED LIMIT IS MUCH MORE DANGEROUS THAN 30 MPH
61. IDOT assigned a 40 MPH speed limit to WRUD some time before 2002 and has
forced WRUD to keep its 40 MPH speed limit, inferior sidewalks, numerous driveways
and local roads, and other dangers while facing ever-increasing traffic on a highway they
recommended be substantially modified over two decades ago.
62. On information and belief, IDOT’s failure to modify WRUD is unlike any of the
other nearby parts of Waukegan Road or any other SRAs created at the same time.
63. The likelihood of death at WRUD’s 40 MPH is much greater than for Plaintiff’s
neighbors with a 30 MPH. It is also much higher at 30 MPH than at 25 MPH.
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64. Over the past seventeen years, not one statement by IDOT regarding WRUD has
considered those live on WRUD, much less all of Northbrook which is split by vehicles
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
running down WRUD at speeds up to over 80 MPH. IDOT’s sole focus is and has been the
vehicles that speed by Plaintiff’s house and drive on the same street Plaintiff is forced to
drive on every day.
65. IDOT has intentionally put Plaintiff and others on and near WRUD at much
greater risk of death and injury than those living, walking and working in neighboring
municipalities with 30 MPH and lower speed limits on better highways than WRUD.
66. Instead of encouraging improved urban life, health and the vitality of Northbrook
residents as IDOT has done in neighboring municipalities, IDOT has discriminatorily
imposed their deadly speed limit on downtown Northbrook and vicinity, discouraging
walking and bicycling in and around downtown Northbrook with no consideration
whatsoever to Northbrook’s many requests on behalf of those of us who live in WRUD
and who use and cross it every day.
E. IDOT ALLOWS WRUD SPEEDING
67. IDOT fails to consider its speed limits in municipalities as its responsibility or
required by law.
68. Although the speed limit on WRUD is 40 MPH, speeds on WRUD are far in excess
of that limit.
69. From 50% to over 90% of drivers moving with so-called free-flowing traffic have
been found to drive over the speed limit on WRUD. (All statistics in this section are from
Group Exhibit 4.)
70. Up to over 90% of WRUD vehicles tested since 2002 drive right in front of the
junior high school at the highest speeds on all of WRUD.
015
71. Of the very few speeders stopped due to sporadic and ineffective enforcement by
Northbrook Police, two drivers in WRUD were caught during a recent three-month period
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
in 2017-18 going 75 MPH or higher.
72. IDOT has recognized that it is responsible for enforcement of the speed limits on
WRUD but has claimed that it can defer to Northbrook for such enforcement.
73. IDOT has tried to get the Northbrook Police to clamp down on speeding on WRUD
since 2002 without success. (Letters from IDOT to Northbrook Police, Group Exhibit 5)
74. IDOT is satisfied if an average of 50% of vehicles measured at four places on
WRUD are “complying” with its speed limits.
75. On information and belief, IDOT did not request “selective enforcement” in 2015
despite speed tests averaging over 50% violations for the entire length of WRUD.
76. IDOT has argued that there is no point in lowering the speed limit because drivers
will still speed.
77. IDOT has never considered how fast these violators are going. The speeds involved
are material to its Speed Policy insofar as they may mean the right speed limit should be
over 40 MPH, not lowered.
78. IDOT determines the percentage of violations with distorted samples of traffic that
purposefully ignore “too fast” speeders from the “average” “traffic flow.”
79. In 2007, despite finding that a 45 MPH speed limit was appropriate, IDOT said
that “selective enforcement” was required for the 71.1% violation rate and kept the 40
MPH speed limit.
016
F. SPEEDING IS WORST BETWEEN MAPLE AND WALTERS
80. Over 1,200 students go to elementary and middle schools on and near WRUD,
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
including St. Norbert School, Meadowbrook Elementary School and Northbrook Junior
High School (“NBJH”).
81. Many of the students at these schools come from east of Waukegan Road. Most
students who walk and ride bicycles and are driven, including those on buses, turn from
or traverse WRUD onto Maple and Walters Avenues.
82. Although IDOT has claimed that motorists “only” engaged in a “violation rate” of
48.8% on all of WRUD in its 2013 speed tests, violation rates have exceeded 50% in
front of NBJH every year speeds were tested since 2002.
83. Not only do over 50% of drivers speed at or above 40 MPH, some of the worst
speeding has occurred in front of NBJH. Of the few who are caught, some have been
speeding at over 75 MPH.
G. NBJH DID NOT GET A SCHOOL SPEED ZONE DUE TO FICTITIOUS “FUNNELS”
84. In 2017, School District 28 requested IDOT assign a school speed limit to
Waukegan Road near NBJH.
85. According to IDOT’s review, students use two “funnels” and are therefore safe
along WRUD. (May 30, 2017 IDOT Letter to Larry Hewitt (Group Exhibit 5))
86. One of these “funnels” is on a two-lane road with no sidewalks and without space
next to the roadway for walking.
87. The principal reason for the rejecting the school speed zone is the fake funnels.
88. There is and was no proof that most of the analysis is valid.
89. IDOT made no effort even to talk with District 28 or the schools involved before
rendering their “safety” decision.
017
90. IDOT’s attitude is the same with this issue as with all other WRUD decisions. No
one matters to IDOT if they are not driving and then only if they are in the “traffic flow.”
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
91. The vehicles must go on no matter their speed. In fact, their speed means that the
speed limit may be too low, not too high.
H. IDOT IS SATISFIED WITH LITTLE TO NO NORTHBROOK POLICE ENFORCEMENT
92. Speed limit enforcement has failed and is of no interest to IDOT.
93. On information and belief, the Northbrook Police regularly and systematically fail
to enforce speed limits on WRUD.
94. On information and belief, IDOT also knows that the Northbrook Police and most
other police departments do not stop speeders who travel at or below 10 MPH over the
speed limit, intentionally imposing a 50 MPH speed limit on WRUD in and near
downtown Northbrook.
95. Over more than the past three years, Plaintiff has never seen a Northbrook Police
vehicle hiding on a municipal road leading into WRUD to enforce the 40 MPH speed limit.
The only regular location for enforcement is south of WRUD, where the speed limit
increases to 45 MPH.
96. Plaintiff has seen Northbrook Police in different parts of WRUD for brief periods
of time, but even these small, meaningless efforts make no difference in the speed apart
from the periods when these police were visible.
97. The only recent speeding abatement effort on WRUD was a Northbrook Police
SUV parked on the entire sidewalk, jutting nearly into the street.
98. On information and belief, the rest of the time speeds at and over 50 MPH prevail
for “free flowing” WRUD traffic.
018
99. IDOT knows that no significant enforcement will occur on WRUD if only because
it is very difficult to control speeds on WRUD, especially for a police force that cannot
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
constantly police the speeding with no other assistance from IDOT and any
reconfiguration or change in the roadway.
100. Since IDOT believes that speeders seek their natural speed at which they are most
comfortable, IDOT knowingly allows thousands of speeders a day on WRUD and has
threatened that it can raise the speed limit to 55 MPH because speeders, including high
school students and seniors, not IDOT, know the speed on WRUD that is safe.
101. Plaintiff and others living on WRUD face these risks 24 hours a day 7 days a week
on a roadway with a police force and state agency that do little to nothing to discourage
speeding.
I. REMOVAL OF PARKING MADE WRUD LESS SAFE FOR PEDESTRIANS
102. What had previously been a parked car buffer near Shermer Road on WRUD was
removed in or about 2008 to accommodate a bank and a Walgreens.
103. After this, on information and belief, a car flipped onto another vehicle from
Waukegan Road.
104. Together with losing the parked vehicles, WRUD was less safe by 2008 for
pedestrians and bicyclists than it had been previously.
J. STANCHIONS AT SHERMER AND WAUKEGAN MADE WRUD LESS SAFE
105. IDOT has also forced huge stanchions onto an already narrow sidewalk corner on
the southeast corner of Waukegan Road and Shermer Road as partially seen in the picture
below.
019
106. The picture is of an October 17, 2018 three-vehicle accident at this dangerous
intersection with the fireman showing the size and location of the stanchion involved.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
107. Stanchions now reduce the size of WRUD sidewalks so that it is difficult if not
impossible for younger, larger and disabled people to walk bicycles and get wheelchairs
to the corner.
108. The sloppy, ill-considered way these stanchions were added is illustrative of
dangers and problems Plaintiff, WRUD residents, and those who live nearby face from
IDOT.
K. THE LIGHTS AT WALTERS AVENUE AND VOLTZ ROAD INCREASED SPEEDING
109. On information and belief, the installation of lights and turning lanes at Walters
Avenue and Voltz Road and maintaining 40 plus MPH speeds in front of NBJH have
increased speeding by removing vehicles from delays for free-flowing traffic, sending
more traffic by Maple Avenue at greater speeds when the lights are green.
110. The currently planned turn lane at Maple Avenue will have the same effect,
increasing illegal speeding even more because there is no light at that intersection and
traffic being slowed by turning vehicles will be able to go even faster.
020
L. FLAT PARKWAYS WERE APPROVED NEAR SCHOOLS DESPITE KNOWN DANGERS
111. The school bus company serving the school near WRUD has identified Waukegan
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Road as a dangerous road, allowing elementary school children inside a mile radius of
their grade schools to ride a bus rather than walk or bicycle to school.
112. With the speeds on WRUD, substantial travel from the roadway has happened
and will happen before vehicles can be controlled, much less stopped, when they go off
the roadway.
113. The pictures below depict a 2017 incident in which a vehicle went off the roadway
just missing the sidewalk about a foot from the sidewalk.
114. Previously, an elementary school bus with students coming from nearby
Meadowbrook Elementary School was hit on WRUD resulting in the bus and students
careening into the parkway.
115. It is doubtful that most in IDOT were even aware of the accident when it found
that this was sufficient to find WRUD perfectly safe for students. In fact, whether by
design or incompetence, on information and belief, IDOT does not even maintain a map
of the speed limits in Illinois. On information and belief, IDOT’s records systems and
destruction requirements are out-of-date, ending up in the intentional destruction, loss
or misplacement of relevant information making it impossible to understand or
determine the history of many if not most highways.
021
116. IDOT has agreed that a turn lane is needed at Maple Avenue where the junior high
school is located right next to the road. As with every other WRUD improvement has
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delayed or ignored, IDOT has claimed that it cannot undertake this improvement because
of alleged lack of funds and lack of interest.
117. If the road diet sought by this Complaint is required, however, IDOT will get its
turn lane sooner at much less cost for that one turn lane than otherwise required.
M. IDOT HAS KEPT WRUD IN ITS 1996 CONDITION DESPITE AVAILABLE FUNDS
118. IDOT had as much as $25 million available as of April 2018 when IDOT’s Region
1 asked for private contractors to encourage local agencies to seek these funds for the
Highway Safety Improvement Program.
119. None of these funds reached WRUD, as they have not for over 20 years for most
of the recommended SRA improvements, much less for those even IDOT agrees would
increase safety.
120. On information and belief, IDOT failed to notify Northbrook of the availability of
funds for WRUD because IDOT has animus for Plaintiff, WRUD, Northbrook and perhaps
even Plaintiff’s State Representative.
121. As can be seen by IDOT’s own recommendations, WRUD was not made for the
traffic it carried at the time, much less the speeds Defendants regularly impose on
Plaintiff, his fellow Northbrook residents and all WRUD drivers.
122. Instead, residents like Plaintiff have suffered for decades virtually no
improvement.
123. WRUD remains as the only downtown highway with a purposefully enticing
speed limit that generates wholly inappropriate speeds, with an inferred speed limit well
over the 40 MPH speed limit.
022
124. IDOT has seriously harmed WRUD and Plaintiff by failing to improve WRUD as
planned and maintaining an unacceptably dangerous speed limit and speeds well in
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excess of the speed limit.
125. The only practical and acceptable way to follow the law and achieve speed
abatement according to IDOT itself is to implement some other form of speed
abatement.
N. IDOT HAS MADE WRUD FAR LESS LIVABLE
126. Unlike IDOT’s imposition of excessive speeds and speeding on WRUD,
municipalities have been and are lowering speed limits below 30 MPH to advance safety,
vitality and better living for children, seniors and others, and to encourage walking and
bicycling including to schools like the three schools on and near WRUD.
127. IDOT has purposefully done the opposite, planning on having no pedestrians on
WRUD at all so they can ignore them in their speed limit assessments.
128. IDOT has noted some of the problems with WRUD based on part of a Road Safety
Analysis (“RSA”) for WRUD. IDOT has refused to produce the RSA to anyone outside
IDOT except perhaps the Illinois Attorney General’s Office. On information and belief, an
Illinois Attorney General attorney told IDOT that its withholding of its road safety reports
and analyses would not likely be supported in court.
129. As the National Highway Traffic Safety Administration has said, poorly designed
facilities, speeding, and inadequate separation from motor vehicles are principal culprits
in creating dangerous situations for bicyclists and pedestrians. (NHTSA, Bicyclist and
Pedestrian Safety, Exhibit 6) All these problems exist on WRUD.
023
O. WRUD’S COMPOSITION MAKES SPEEDING MORE DANGEROUS
130. Northbrook’s population, on information and belief, is younger and older than its
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neighbors’ populations.
131. On information and belief, Northbrook has one of the larger concentrations of 15
through 19-year-old teenagers of any nearby municipality, with as many as 10 to 20% of
its teenage population with driving permits or licenses.
132. On information and belief, Northbrook has the largest percentage of seniors of all
the nearby municipalities with as many as 25 to 30% over 55 years old.
133. This places those who use WRUD at greater risk than in nearby communities.
134. Nearly 48% (2,000 of the 4,179) of the pedestrians killed in traffic crashes are
under 19 and over 55 years old nationwide. Also, teenage and senior drivers are the age
groups most likely to have fatal accidents, with seniors 60 and over even higher than
teenagers.
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States 2014-2015.
135. WRUD is more dangerous than the highways in neighboring communities even if
only considering its teenage and senior driver percentages.
024
P. TRUCKS ON WRUD MAKE IT MORE DANGEROUS
136. On information and belief, more construction trucks, semi-trailer trucks, large
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
commercial trucks, and teenage and senior driven vehicles are on WRUD than those on
any nearby community’s SRA.
137. These far less maneuverable trucks drive at the same speed as passenger vehicles
under IDOT’s Speed Policy.
138. On information and belief, they too drive at the excessive speeds recorded by
IDOT and frequently run red lights at Shermer Road and WRUD, just above Plaintiff’s
home.
139. Even if there were the same number of these large vehicles on WRUD as on other
nearby highways, the maneuverability of any vehicle diminishes the faster they go.
140. Trucks and other large vehicles traveling right next to Northbrook sidewalks also
present other dangers.
141. Trucks create suction that can pull pedestrians and bicyclists into the path of such
vehicles.
142. Plaintiff and others have felt suction pulling them and their children toward large
vehicles due to their speed and proximity to their bicycles and when walking along
WRUD, often right next to the roadway.
143. Trucks and other vehicles with protrusions also hit people walking inside of 18
inches away from the vehicles.
144. Many people walk on WRUD sidewalks right next to and on the curb, including
the sidewalk in front of Plaintiff’s house.
145. IDOT recognizes the possibility of vehicles hitting pedestrians because it moves
its signs, street lamps, and other physical objects at least 18 inches away from the curb.
025
146. As Alex Epstein of the Volpe Center, a US Department of Transportation research
arm who spent five years examining how truck design affects bicycle and pedestrian
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
safety, has said (Exhibit 7):
“Nationally it’s more like 3 to 1 — three times as many bicyclists killed. So 11 percent
of bicyclist [fatalities are accounted for] by the 4 percent of vehicles on the road [that]
are trucks. In cities, it’s more disproportionate. In New York City, about 32 percent —
about one out of every three cyclists that are killed — are killed by a truck. And for
pedestrians it’s about one in eight.”
147. On information and belief, Plaintiff and others on and near WRUD experience
trucks speeding in excess of 50 MPH every day.
Q. IDOT’S SPEED POLICY ENDANGERS PLAINTIFF AND OTHERS
148. IDOT has based its refusal to lower the speed limit on WRUD on it’s Speed Policy.
149. IDOT’s Speed Policy allows IDOT to impose speed limits however, wherever and
whenever it chooses without regard to the physical features and location of roadway, and
the dangers to pedestrians, cyclists, and others.
150. Using this policy, IDOT has discriminated against Plaintiff and others who live
on and use WRUD.
151. IDOT analyses using the Speed Policy manipulate and ignore engineering and
traffic data. IDOT allows engineers to ignore the infrastructure involved despite 50 years
or more understanding that there are different speed limit considerations shown by the
sign at paragraph 26 above of which inferred speed is only one.
152. IDOT’s Speed Policy includes many biases oriented toward driver perceptions,
including whether a 16-year-old or someone over 80 is involved. The higher and lower
ages of WRUD drivers than in other nearby communities make reliance on inferred speed
even more dangerous.
026
153. In existence for years in different iterations, IDOT’s Speed Policy not only
precludes a full consideration of these various speed issues, it is discriminatory, not used
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for all speed limits and all locations, intentionally violates state laws, ignores these and
other basic engineering principles, falsifies traffic statistics, violates its own highway rules
and considerations, ignores common sense, precludes any substantial speed limit
reductions, and fails properly to administer engineering and traffic tests conforming with
Illinois statutory requirements of an engineering and traffic study.
154. Under the Speed Policy, when conducting a “speed test” to determine a speed
limit for its highways, IDOT’s Speed Policy unlawfully, among others: (1) requires IDOT
personnel and others to ignore sidewalks and pedestrians; (2) ignores the location of the
highway, whether downtown or in a rural setting in front of a field makes no difference;
(3) ignores sidewalk construction, such as the existence of a curb and the distance of the
sidewalk from the curb or roadway; (4) encourages speeding, including allowing 50% of
the traffic to violate the speed limit before considering any abatement requirement; (5)
permits speed limits over 30 MPH in Urban Districts; (6) places unlawful requirements
on Urban Districts limiting the use and application of Urban Districts in the State of
Illinois; (7) creates unequal treatment of Plaintiff and others in violation of state and
federal law; and (8) uses a test that is not acceptable under Illinois law since it is not
uniformly applied, ignores basic engineering principles, including the very basis of the
85th Percentile Rule, and allows engineers to ignore basic traits of older roadways
insisting on higher speed limits in urban areas like WRUD than the lower speed limits it
requires on far better and safer highways.
155. Under state and federal law, IDOT is required to have pedestrian safety as a top
priority. IDOT’s Long Range Transportation Plan (“LRTP”), Illinois law, and
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Northbrook’s bicycle plan are consistent with a lower speed limit and Plaintiff’s requested
changes to the highway.

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
156. Numerous laws, manuals and other documents show that IDOT is responsible for
those walking on, across and along WRUD. Their obligation is to encourage living, not
discourage living.
157. Living in urban and suburban areas includes merely crossing a highway, walking
down a highway, bicycling across and down a highway, and considering these factors
whenever a speed limit is considered. These considerations must be made equally for all
communities.
158. Despite this responsibility, Defendants direct IDOT engineers to ignore
pedestrian safety and protection on its highways, including specific direction that
pedestrians crossing the highway should be ignored and if there are fewer than 10
pedestrians walking on any stretch of highway then all other pedestrians walking at any
time on any other part of the highway are ignored under its Speed Policy.
159. Thus, many WRUD pedestrians per day are ignored by IDOT under its policy. To
IDOT, these pedestrians do not exist, have never existed, and do not need to be
considered.
160. This refusal to consider pedestrians is endemic to whatever IDOT has done on
WRUD.
161. In any case, even if teeming with pedestrians, IDOT allows at most a 5% reduction
in the speed limit, all things being equal. A 5% reduction to a 40 MPH speed limit is 2
MPH. These acts are ultra vires.
162. On information and belief, there is no support for either eliminating pedestrians
or treating them only worthy of a 5% reduction in a speed limit.
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163. Not one speed test taken since 2002 says anything about pedestrian risks.
164. On information and belief, IDOT largely does not care about pedestrians and the
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interconnectivity of sidewalks along its highways and municipalities involved.
165. Plaintiff offered to allow Northbrook to build a sidewalk on his property away
from Waukegan Road in order to make walking on that part far safer, avoiding the risk of
being hit and providing Plaintiff a place to place his garbage cans. Northbrook refused the
offer.
166. IDOT can easily accidentally or intentionally miscount pedestrians and take other
steps to support the 40 MPH speed limit.
167. There are no audits or any audit trail left to prove this one way or the other.
168. In part, this is because of IDOT’s over 300 document destruction policies have
almost certainly eliminated any data that existed in a short period of time.
R. THE 85TH PERCENTILE AND RELATED RULES SHOULD NOT APPLY TO WRUD
169. Despite numerous conversations and requests, IDOT has failed to recite one
reason why a higher speed is necessary, apart from periodically falsely claiming that this
fake “free flow” is “safer” for drivers.
170. The rule they have cited for this proposition, the 85th Percentile Rule (the “Rule”),
has as its purpose to ensure that a speed limit is set for 85 percent of the vehicles on a
given highway. According to the theory, when vehicles deviate from a standard speed,
either faster or slower, the potential for crashes increases.
171. IDOT’s problem with using this Rule on WRUD is that, with stop lights, the large
number of access points, and turning vehicles, “the potential for accidents increase”
because of different speeds on the highway. The Rule says so.
029
172. This leaves completely aside the exclusion of vehicles that the tester is required
to eliminate because they go “too slow” or “too fast.”

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173. IDOT is a strong supporter and possible inventor of the Rule.
174. On information and belief, IDOT has continued to fight for the use of the 85th
Percentile Rule at the federal level in recent years including last year.
175. While the viability of the Rule even for limited access, divided highways is now
questioned, no reasonable engineering supports IDOT’s use of the Rule on WRUD and
other similar highways.
176. The very definition of the Rule says otherwise, leaving aside conflicting traffic
engineering rules, and common sense.
177. The Rule therefore largely mirrors IDOT’s exclusive use of inferred speed limit for
WRUD and is ultra vires.
178. This is particularly inappropriate for WRUD given, among others, the many
defects in the roadway and appurtenances, the nature of the roadway, the 200 or so access
points under IDOT’s method of counting, its sightlines, its 50 plus MPH speeds and the
40 MPH speed limit being too fast for the required stopping distance for the signal at the
hill at Shermer Road and WRUD.
179. At this point, by far the predominant consideration for speed limits is context.
(Ite Journal, Speed Limits: Leading to Change, p. 38, 40; Exhibit 8)
180. Yet, the context for IDOT has been defined out of existence for those who do not
care about its application in any given situation, and for those with little or no interest in
considering these points.
181. IDOT cannot factually claim that considerations required by a Speed Policy in
existence since at least 1977 and likely long before are the same as recognized by modern
030
engineering and traffic studies of today. Yet they cling to their “guns,” finding that risks
are acceptable based on theories never valid for the roadways on which they are
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occasionally applied and even less followed today.
182. There is no known scientific reason to limit a speed reduction to 5 MPH, or to
reduce speed even if hundreds of pedestrians are on WRUD and other highway sidewalks
by only 2%, much less to do IDOT’s best to refuse any reductions due to speeding on a
highway like WRUD. Yet these are “studies” they implement today for WRUD and
presumably at least a few other similar highways.
183. In this, IDOT has utterly refused to consider a single criterion other than its
limited consideration of “access points” about which its Region 1 Engineer went so far as
to say there were somehow just not enough for an Urban District, an absurd observation
and unlawful position at best, as well as accidents occurring on WRUD from time to time.
S. IDOT USES DIFFERENT STANDARDS FOR WRUD THAN FOR ITS NEIGHBORS
184. Plaintiff’s State Representative Gabel has requested a lower speed limit for
WRUD and Northbrook has done so many times without success.
185. Instead of agreeing to reduce the speed limit for the safety of those in Northbrook,
IDOT has used the Rule inferring the proper driving speed, speeding on WRUD, and the
lack of speeding enforcement as reasons to keep the speed limit higher than elsewhere.
186. To IDOT, what happens in the middle of a municipality is dictated not by the
highway or its location but by whether and how it applies its “Speed Policy” that fails to
require any consideration of where it is and the condition of the highway.
187. Yet this is not true of other highways nearby.
031
188. In St. Charles, on Willow Road in Northfield, near the Deerfield High School, and
on information and belief elsewhere, other municipalities have been allowed to lower
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their speed limits for safety.
189. In each instance, IDOT imposed lower speed limits to slow traffic down and for
safety reasons.
190. In St. Charles, the speed limit reduction was reportedly sought “in an effort to
calm traffic” and for safety. (Group Exhibit 9)
191. Ironically, once IDOT improves a road, it frequently lowers the speed limit. For
example, on Woodstock’s Route 14, IDOT lowered the speed limit after it changed the
highway from a two-lane unseparated roadway to its current four-lane road with two
separate two-lane roadways separated by a barrier. (Group Exhibit 9) Speed reduction
also occurred in Northfield on Willow Road from 35 to 30 MPH.
192. This contrasts with what has been done with WRUD. Even with the very small
sample due to unlawful limitations IDOT placed on Plaintiff’s Freedom of Information
Act requests, Plaintiff has found that IDOT (1) lowered speed limits in front of Deerfield
High School for safety but refused to do so for the safety of School District 28 parents and
students in Northbrook, and (2) lowered the speed limit on Dundee Road from Interstate
94 west to beyond the railroad tracks due to a request by a state senator but refused to
lower the speed limit for Plaintiff’s State Representative Gabel for WRUD.
193. The speed limit was reduced on Dundee Road in Northbrook despite the
requirements of the Speed Policy and an over 80% anticipated violation rate. But on
Northbrook’s section of Waukegan Road in and near downtown, IDOT claims that WRUD
requires a 40 MPH speed limit under the Speed Policy because the traffic goes too fast to
do anything else without even considering the highway’s design speed.
032
194. Even as to this statement, IDOT is not telling the truth. In fact, there are ways in
which it could impose a 30 MPH speed limits based on the roadway through traffic
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calming. Most of these methods would require vigilance with manpower the Northbrook
Police could never afford. But the road diet sought by this Complaint would force lower
speeds on WRUD drivers without police enforcement.
195. IDOT’s use of deficient and manipulative calculations to determine speed limits
due to the mandatory Speed Policy violates the Illinois law requirement that these be done
with “engineering and traffic studies.” In fact, the Speed Policy violates IDOT’s own rules
and unlawfully limits reductions in a variety of ways and cannot possibly satisfy this
requirement.
196. IDOT does not uniformly apply IDOT’s Speed Policy.
197. The Speed Policy is designed to allow deviations for favored communities and
state legislators.
198. IDOT encourages far more dangerous speeds on WRUD through this
discrimination.
T. PLAINTIFF’S FRUITLESS EFFORTS BEFORE FILING THIS COMPLAINT
199. Plaintiff has spent more than three years living on WRUD, and more than two
years reviewing facts and law related to IDOT’s implementation of speed limits and the
configuration of WRUD.
200. Plaintiff has pointed out the applicable law to IDOT, his legislators and the
Village of Northbrook, referred repeatedly to the absurdity of a policy that allows IDOT
engineers to ignore the design, age, location, defects, and type of highway involved, and
compared other highways near WRUD.
033
201. On information and belief, Plaintiff is being forced to file this case so IDOT can
defend its Rule and never have to consider problems with its highways as a reason to lower
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
its speed limits.
202. IDOT’s 40 MPH speed limit decisions have never been rooted in fact or law.
203. On information and belief, Plaintiff is and has been a target of a campaign to
harm him and consequently WRUD residents.
204. Plaintiff has been told repeatedly that he would receive a response to the 144-
page Report he provided to IDOT. The last efforts made for this response were this year
when IDOT refused to discuss any problems it had with prior drafts of this Complaint, in
much the same way he was treated in 2017.
205. Northbrook has no control over WRUD’s configuration or any of IDOT’s actions.
206. IDOT is obligated to act in the best interests of Plaintiff and all others on and
near WRUD, including Northbrook. IDOT has failed to act in their best interests. No one
else can.
U. IDOT’S FAILURE TO IMPLEMENT TRAFFIC CALMING MEASURES
207. On February 1, 2019, an IDOT representative on the telephone with Plaintiff
agreed that traffic calming had to occur on WRUD.
208. IDOT’s refusal to ensure the speed limit on WRUD is enforced has included its
failure to implement traffic calming efforts beyond its useless effort to get the Northbrook
Police to undertake “selective enforcement.
209. Although it has recently implemented traffic calming on Shermer Road near
WRUD by including a sign that shows the speeds at which vehicles are traveling, IDOT
has not even implemented that minimal effort.
034
210. Illinois includes traffic calming as the second most important way to reduce
speeding to protect pedestrians, with the most important way to implement a road diet.
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(Illinois Strategic Highway Safety Plan 2017 - Objectives And Strategies To Address
Pedestrian Crashes (Exhibit 10))
V. A ROAD DIET WITH 25 AND 30 MPH SPEED LIMITS IS REQUIRED
211. According to IDOT, lowering the speed limit would not afford the kind of
protection needed in light of (1) the history of non-enforcement of those speed limits
and/or (2) IDOT’s claim that enforcement will not be effective.
212. By reducing the speed limits to appropriate speed limits for the context, as is
preferred today, IDOT would immediately protect the public, enhance livability and
protect motorists alike on WRUD.
213. IDOT itself has called for a turn lane at Maple Avenue for the junior high school
but has not built the lane because of what it claims is a lack of funds. A road diet will create
a center turn lane in front of NBJH satisfying this need.
214. Given IDOT’s inability or refusal adequately to control vehicles so its speed limit
is maintained in WRUD, and IDOT’s own admission, the means by which this Court can
ensure the safety of everyone along WRUD is to reduce the speed limit and to made the
four-lane undivided unlimited access highway into one that has two lanes, a middle
turning lane and bicycle lanes with adequate parkways. The reduction of lanes is called a
“road diet.”
215. Together with a concomitant change in the speed limit, speeds in WRUD will be
substantially reduced. The space provided by the eliminated lane will promote WRUD’s
integration into Northbrook. Bicycling and walking will be facilitated, a national and
Illinois objective by law.
035
216. Undertaking the speed reduction by lowering the speed limit will involve much
less expense than the SRA changes identified in 1996, allowing the immediate
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incorporation of the turn lane at Northbrook Junior High School that IDOT has said is
important for safety but which will not be installed for years and in any case is more likely
to increase speeding in front of NBJH rather than reduce it without a road diet.
217. A road diet would require painting the roadway to create three lanes including a
turn lane and creating two bicycle lanes and other improvements when IDOT resurfaces
WRUD. A road diet could be implemented at very little cost compared to other remedies.
IDOT’s comments suggest it is the only viable method to decrease speeds permanently.
218. The timing is critical at this point. IDOT has planned to go forward with
resurfacing the roadway in the near future. In addition, the road surface could be far less
noisy if the surface were made of more quiet materials. Even if not, there is less noise and
pollution the lower the speeds and speed limits on WRUD.
219. If resurfacing WRUD does not include the lower speed limits, a road diet and
other improvements, then another twenty years or more will likely go by before these
improvements might be obtained. IDOT shows every intention of doing this for the rest
of the WRUD’s useful lifetime.
220. Plaintiff has nowhere else to turn. He is not alone with his views. But he is the
only one with the time and ability to file this lawsuit to redress the wrongs he and others
face.
036
PLAINTIFF’S CAUSES OF ACTION
COUNT I
Violation of 625 ILCS 5/11-601 and 5/11-602
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
WRIT OF CERTIORARI ENJOINING IDOT FROM USING

SPEED LIMITS OVER 30 MPH IN URBAN DISTRICTS
221. Count I seeks a common law writ of certiorari to preclude IDOT’s ultra vires acts
in allowing speed limits over 30 MPH in Urban Districts and similar parts of Illinois
highways, including in WRUD.
222. Plaintiff hereby realleges and repeats every allegation contained in paragraphs 1
through 220 as if fully set forth in Count I.
223. On January 1, 2014, the 30 MPH speed limit in Urban Districts became
mandatory.
224. Under the Illinois Vehicle Code, 625 ILCS 5/11-602, IDOT may undertake an
“engineering and traffic investigation” to determine if “a maximum speed limit prescribed
in Section 11-601 of this Chapter is greater or less than is reasonable or safe with respect
to the conditions found to exist . . . along any part or zone” of “any highway for which
[IDOT] has maintenance responsibility.”
225. Before January 1, 2014, Section 11-602 of the Illinois Vehicle Code (625 ILCS
5/11-602) allowed IDOT to raise or lower speed limits in Urban Districts. The statute
limited the maximum speed limits recited in Section 11-601 to 55 and 65 MPH.
“[S]uch limit shall not exceed 65 miles per hour on a highway or street which is
especially designed for through traffic and to, from, or over which owners of or persons
having an interest in abutting property or other persons have no right or easement, or
only a limited right or easement, of access, crossing, light, air, or view, and shall not
exceed 55 miles per hour on any other highway.”
226. The amended statute, effective January 1, 2014, substantially changed this
language and its coverage. The new statute precluded IDOT from raising speed limits in
Urban Districts and all other speed limits established by Section 11-601.
037
“However, such limit shall conform with the maximum speed restrictions provided for
in Section 11-601 of this Code not exceed 65 miles per hour on a highway or street
which is especially designed for through traffic and to, from, or over which owners of
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
or persons having an interest in abutting property or other persons have no right or

easement, or only a limited right or easement, of access, crossing, light, air, or view,
and shall not exceed 55 miles per hour on any other highway.”
227. The maximum speed limit for Illinois highways in Urban Districts is 30 MPH
under IVC, Section 11-601. This speed limit cannot be raised by IDOT above 30 MPH. It
can only be lowered.
228. Any such change “must conform with” the maximum speed limits in Section 11-
601, including those of “Urban Districts.” Thus, the only change for Urban Districts
possible after January 1, 2014, was and is to lower the speed limit to or below 30 MPH.
229. In response to adding the mandatory 30 MPH maximum speed limit for Urban
Districts, IDOT amended its 2014 Speed Policy.
230. In that new Speed Policy, in direct contravention of applicable law, IDOT
directed its employees to either maintain the 30 MPH limit or to change that speed limit
to any speed limit “until the anticipated violation rate is equal or less than 50 percent.”
“If the anticipated violation rate exceeds 50 percent, the proposed altered speed limit
should be revised in 5 mile per hour increments until the anticipated violation rate is
equal or less than 50 percent. If this results in a proposed altered speed limit which
exceeds a 30 mph statutory speed for the highway in question, either the
statutory speed or the proposed altered speed may be used to set the
speed limits.” (Emphasis added.)
231. The Speed Policy and any other instructions that IDOT employees can exceed the
maximum 30 MPH speed limit in Urban Districts in Section 2-601 are ultra vires.
232. Urban Districts were specifically aimed at lowering speed limits in municipal
areas. Thus, Section 2-202 of the Illinois Highway Code (605 ILCS 5/2-202) provides:
“The term "highway" includes rights of way, bridges, drainage structures, signs, guard
rails, protective structures and all other structures and appurtenances necessary or
038
convenient for vehicular traffic. A highway in a rural area may be called a "road", while
a highway in a municipal area may be called a "street".
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
233. Without a writ of certiorari, Plaintiff would be unable to limit the speed limit on
WRUD even though WRUD satisfies the requirements of an Urban District as Plaintiff
contends it does.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter an order:
A. Declaring that Defendant use of speeds higher than 30 MPH in Urban Districts is
ultra vires;
B. Requiring IDOT to eliminate all text in the Speed Policy and elsewhere allowing
IDOT employees and others to set a speed limit higher than 30 MPH in Urban
Districts; and
C. Enjoining IDOT from setting speed limits in WRUD and other Urban Districts over
30 MPH.
COUNT II
WRIT OF CERTIORARI ENJOINING IDOT FROM ALL
NON-STATUTORY LIMITATIONS TO URBAN DISTRICTS
234. Count II seeks a Writ of Certiorari enjoining IDOT from all non-statutory
limitations it has placed on WRUD and other Urban Districts.
through 233 as if fully set forth in Count II.
236. IDOT has unlawfully added more requirements to the Urban District statute than
established by statute, and contorted or ignored other parts of the statute, to eliminate
many if not most Urban Districts in the State of Illinois.
039
237. On information and belief, IDOT’s definition of “Urban District” in its 1977 Speed
Policy included the statement: "The structures referred to in the definition should include
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
only those that have direct access to the highway." Sometime after the court in City of
Geneva v. Ory, 89 Ill.App.3d 1118 (Dist. 2 1980), quoted this language affirmatively, it
was removed from the Speed Policy.
238. The change in the law effective January 1, 2014, requires a 30 MPH speed limit
in Urban Districts.
239. In response, IDOT published a new Speed Policy that added the language in the
older Speed Policy back into its 2014 Speed Policy and also added other language below
imposing the non-statutory limitations in italics below.
“’Urban District’ is defined in Section 1-214 of the IVC as ‘The territory contiguous to
and including any street which is built up with structures devoted to business, industry
or dwelling houses situated at intervals of less than 100 feet for a distance of a quarter
of a mile or more.’ Note that whether the street or highway in question is inside or
outside of the corporate limits of a community is not included in this definition and
therefore, is not applicable to the determination of where such statutory speed applies.
This means that the statutory speed on an unposted street within the corporate limits
of a community but outside an urban district would be 55 miles per hour. Also note
that the structures referred to in the definition include only those that
have direct vehicular access to the highway. Structures on both sides of
the highway should be counted together in determining the interval.”
240. The limitations in italics, added by IDOT in 2014 for all determinations as to
whether an Urban District exists, are not and have never been in the Illinois statute.
Plaintiff has found no statements at all similar to these sentences in any law or
engineering analysis. For some reason, added language included the old language used in
1977.
241. In its only statement regarding why WRUD is not an Urban District, IDOT’s
Region 1 Engineer added another requirement, holding: “The Department has verified
040
that access points along IL 43 do not meet the definition of an Urban District.” (IDOT
Letter from A. Quigley of IDOT to S. Frum of Northbrook, May 2017; Group Exhibit 4)
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242. IDOT has interpreted Urban Districts in an ultra vires manner, including a
requirement not included in the Speed Policy that IDOT declared was sufficient by itself
to find that finding WRUD an Urban District would be unlawful.
243. IDOT limitations on Urban Districts are ultra vires, largely eliminate them from
the State of Illinois despite the clear and unambiguous legislative mandate to the
contrary.
244. IDOT policy ignored the provisions of the Urban District statute that make it
clear that a “territory” is covered, not just a section of its highway.
245. These limitations have affected the size and existence of any Urban District on
WRUD and elsewhere throughout the State of Illinois.
246. The use of the word “territory” is inconsistent with ignoring any structures or
streets as if they terminate the existence of an Urban District. In fact, according to IDOT,
no “territory” is involved and even the state highway itself can be manipulated to find no
proper Urban District.
247. The legislature could not possibly have passed the Urban District provision in
order to limit safety on Illinois highways, precisely how Defendants have interpreted the
statute.
248. As a statute designed to promote safety, the statute should be interpreted to
ensure that its goals of safety, vitality and enjoyment are not limited by interpretations
that confine it to perhaps many fewer locations around the State of Illinois.
249. The legislation includes streets intersected a state highway. The reference to
streets means that they were part of any Urban District territory.
041
250. It is likely that the 100-foot limitation was not intended strictly to require
precisely 100 feet between structures. Otherwise, one building that were 101 feet would
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
cease the Urban District speed limit. At the very least, IDOT must interpret the Urban
District law within its spirit, providing for 30 MPH speed limits for safety and consistent
with the way lower speed limits are imposed on downtown and concentrated parts of a
state to minimize accidents and make those areas more livable.
251. The legislation plainly does not require any particular number of access points
into any given state highway to make it an Urban District. On the other hand, the high
number of access points is reason enough to make WRUD an Urban District.
252. IDOT has unlawfully treated “a territory” as if it were only its highway and none
of the streets or surrounding community thereby limiting the application of the Urban
District definition to WRUD.
253. In fact, the statute specifically includes streets and could not have believed that
an urban area with many streets would not qualify as an Urban District because the streets
are four lanes, making the structures on each side of such a street more than 100 feet
apart.
254. Nothing in the statute limits the location of the structures, acting as if structures
on streets or backing the state highway involved are to be ignored. Doing so would
discriminate against those who use the highway, including those who must use the state
highway because their streets have no other exit.
255. The State of Illinois legislature is neither stupid or so ignorant as to find that an
area with homes and businesses along a state highway even in a downtown is not intended
to be an Urban District, as if it intended specifically to exclude almost every possible area
for the reasons IDOT makes up.
042
256. Without a writ of certiorari, Plaintiff would be unable to limit the speed limit on
WRUD based on a finding that WRUD satisfies the requirements of an Urban District.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
PRAYER FOR RELIEF
A. Finding that IDOT’s limitations precluding Urban Districts in Northbrook and
elsewhere are contrary to Illinois law;
B. Declaring that IDOT’s Speed Policy is ultra vires; and
C. Enjoining IDOT from conduct that limits Urban Districts in any way other than as
provided by law.
COUNT III
WRIT OF CERTIORARI REQUIRING IDOT TO
CLASSIFY WRUD AS AN URBAN DISTRICT
257. Plaintiff brings Count III for a writ of certiorari requiring IDOT to classify WRUD
an Urban District.
through 256 as if fully set forth in Count III.
259. WRUD is an Urban District under Illinois law. IDOT falsely claims it is not an
Urban District in violation of state law by using its definitional limitations.
260. An Urban District is: (1) a territory; (2) contiguous to and including any street;
(3) built up with structures devoted to business, industry or dwelling houses; (4) situated
at intervals of less than 100 feet; (5) for a distance of a quarter of a mile or more. (625
ILCS 5/1-214)
261. The speed limit in Urban Districts is required to be 30 MPH or lower.
043
262. IDOT has illegally provided a 40 MPH speed limit in WRUD and allows well over
50 MPH speeds to prevail on WRUD.

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
263. On information and belief, some or all of WRUD is a territory satisfying the
requirements of the Urban District statute.
264. Because of its short distance and other factors, IDOT should be required to treat
WRUD as an Urban District.
PRAYER FOR RELIEF
A. Finding that WRUD is an Urban District;
B. Finding that WRUD should have a 30 MPH speed limit on all parts other than from
Kiest Avenue to Chapel Road;
C. Finding that WRUD from Kiest Avenue to Chapel Road should have a 25 MPH
speed limit; and
D. Finding that a road diet must be used on WRUD at least from Kiest Avenue to
Chapel Road to help ensure that the speed limits imposed are followed.
COUNT IV
Violations of 625 ILCS 5/11-601 and 11-602
WRIT OF CERTIORARI ENJOINING IDOT FROM PERMITTING ILLINOIS VEHICLE CODE
VIOLATIONS AND REQUIRING IDOT TO ENFORCE SPEED LIMITS ON WRUD
265. Plaintiff brings Count IV pursuant to 625 ILCS 5/11-601 and 11-602 of the IVC.
through 264 as if fully set forth in Count IV.
267. IDOT has failed to enforce the speed limit on WRUD over the past 17 or more
years. Such acts are ultra vires, directly contrary to the requirements of the IVC.
268. IDOT must be required to enforce WRUD speed limits.
044
PRAYER FOR RELIEF

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
A. Enjoining IDOT from allowing speeds on WRUD in excess of its speed limits
E. Finding that WRUD should have a 30 MPH speed limit on all parts other than from
F. Finding that WRUD from Kiest Avenue to Chapel Road should have a 25 MPH
speed limit;
B. Finding that a road diet must be used on WRUD at least from Kiest Avenue to
Chapel Road to help ensure that the speed limits imposed are followed; and
C. Requiring IDOT to enforce these speed limits on WRUD.
COUNT V
Violations of 625 ILCS 5/11-208.1
WRIT OF CERTIORARI ENJOINING VIOLATION OF THE ILLINOIS VEHICLE CODE
AND REQUIRING IDOT TO USE A 30 MPH AND LOWER SPEED LIMIT ON WRUD
269. Plaintiff brings Count V pursuant to 625 ILCS 5/11-208.1 of the IVC, which
provides:
The provisions of this Chapter of this Act, as amended, and the rules and regulations
promulgated thereunder by any State Officer, Office, Agency, Department or
Commission, shall be applicable and uniformly applied and enforced throughout this
State, in all other political subdivisions and in all units of local government. [Unless
otherwise indicated, emphasis is added throughout this Complaint.]
through 268 as if fully set forth in Count V.
271. IDOT has singled out Plaintiff and WRUD for unequal application of Chapter 11
of the IVC in violation of Illinois law for each of the following reasons, among others: (1)
allowing a lower speed limit for better state highways in neighboring communities; (2)
using different criteria to retain, to lower and/or to raise speed limits in the State of
045
Illinois, and in particular those relating to WRUD; and (3) failing to lower the speed limit
on WRUD consistent with other state highways with lower speed limits.
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272. IDOT has assigned lower speed limits in St. Charles, Deerfield, Glenview, other
municipalities and on Dundee Road using criteria not used for WRUD.
273. IDOT’s use of different criteria to Illinois state highways to determine proper
speed limits is ultra vires in light of 625 ILCS 5/11-208.1.
274. These failures have allowed IDOT to maintain unlawful speeds on WRUD in
Northbrook and elsewhere throughout the State of Illinois.
275. IDOT must stop these illegal differences, allowing for the same or lower speed
limits on WRUD on proper, fully implemented traffic investigations for those parts of
Waukegan Road not found to be Urban Districts.
276. Given the condition of WRUD and its location in and very near downtown
Northbrook, the speed limit on Waukegan Road should be lower than the 30 MPH speed
limits in Glenview, Deerfield and Northfield, not higher.
PRAYER FOR RELIEF
A. Finding that WRUD should have a 30 MPH speed limit on all parts other than from
B. Finding that WRUD from Kiest Avenue to Chapel Road should have a 25 MPH
speed limit;
C. Finding that a school speed zone should be applied from north of Walters Avenue
to Voltz Road; and
046
D. Finding that a road diet must be used on WRUD at least from Kiest Avenue to
Chapel Road to help ensure that the speed limits imposed are followed.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
COUNT VI
Violation of 14th Amendment’s Equal Protection
Clause Under the US Constitution
WRIT OF CERTIORARI ENJOINING IDOT FROM VIOLATING THE
EQUAL PROTECTION CLAUSE OF THE US CONSTITUTION REGARDING WRUD
277. Plaintiff brings Count VI for a writ of certiorari seeking to stop IDOT violation of
the equal protection clause of the US Constitution.
278. Plaintiff realleges and repeats every allegation contained in paragraphs 1 through
276 as if fully set forth in Count VI.
279. Under the 14th Amendment of the United States Constitution, “[n]o State shall
. . . deny to any person within its jurisdiction the equal protection of the laws.
of the IVC in violation of Illinois law for each of the following reasons, among others: (1)
allowing a lower speed limit for better state highways; (2) using different criteria to retain,
to lower and/or to raise speed limits in the State of Illinois, and in particular those relating
to WRUD; and (3) failing to lower the speed limit on WRUD consistent with other state
highways with lower speed limits.
281. Plaintiff has been denied equal protection of the laws because IDOT has lower
speed limits on state highways in Glenview, Northfield and Deerfield than the 40 MPH
speed limit on WRUD.
PRAYER FOR RELIEF
A. Finding that IDOT has violated the equal protection clause of the US Constitution;
047
B. Requiring IDOT to place a 30 MPH speed limit on all parts of WRUD other than
from Kiest Avenue to Chapel Road;

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
to Voltz Road; and
D. Requiring IDOT to place a 25 MPH speed limit on WRUD from Kiest Avenue to
Chapel Road.
COUNT VII
Violation of Equal Protection Under the Illinois Constitution
WRIT OF CERTIORARI ENJOINING IDOT FROM VIOLATING THE
EQUAL PROTECTION CLAUSE OF THE ILLINOIS CONSTITUTION REGARDING WRUD
282. Plaintiff brings Count VII for a writ of certiorari seeking to stop IDOT violation
of the equal protection clause of the Illinois Constitution.
281 as if fully set forth in Count VII.
284. Under Article I, Section 2 of the Constitution of the State of Illinois, “No person
shall . . . be denied the equal protection of the laws.”
of the IVC in violation of Illinois law for each of the following reasons: (1) allowing a lower
speed limit for better state highways; (2) using different criteria to retain, to lower and/or
to raise speed limits in the State of Illinois, and in particular those relating to WRUD; and
(3) failing to lower the speed limit on WRUD consistent with other state highways with
lower speed limits.
PRAYER FOR RELIEF
048
A. Finding that IDOT has violated the equal protection clause of the Illinois
Constitution;
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to Voltz Road; and
Chapel Road.
COUNT VIII
Violation of 625 ILCS 5/11-602
WRIT OF CERTIORARI REQUIRING IDOT
TO APPLY A ROAD DIET TO WRUD
286. Plaintiff brings Count VIII for a writ of certiorari to stop IDOT’s violations of 625
ILCS 5/11-602 for failing to use proper engineering and traffic investigations for WRUD
and all other Illinois state highways, and to require traffic calming measures including a
road diet for WRUD.
285 as if fully set forth in Count VIII.
288. To increase, reduce or maintain speed limits consistent with the objectives of
safety and mobility for all who travel by vehicle and walk throughout the State of Illinois,
IDOT is required under 625 ILCS 5/11-602 to conduct “an engineering and traffic
investigation concerning any highway for which the Department has maintenance
responsibility” before it can impose or change the speed limit on any highway.
049
289. By law, such an engineering and traffic investigation must satisfy basic
engineering requirements, including an investigation of all traffic and a proper

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understanding of the roadway on which the speed limit is being investigated.
290. Speed limit decisions regarding WRUD were made in 2002, 2007, 2013, 2014,
2015, 2016 and 2017, all of which kept a 40 MPH speed limit on WRUD.
291. Each decision regarding WRUD’s speed limit was based on spot speed studies
done according to the Speed Policy with no consideration of the design, age, location and
type of highway involved.
292. IDOT also ignored state and federal requirements that it consider the safety of
pedestrians when considering a speed limit.
293. IDOT has imposed an unsafe highway on Plaintiff and others in WRUD despite
knowing of the improvements necessary to achieve adequate safety.
294. IDOT has made speed limit decisions that differ from those found in its tests.
Thus, it can and does find that lower speed limits are appropriate on roads with features
that are indistinguishable from each other.
295. Despite the requirement that there be an “engineering” investigation, IDOT’s
Speed allows its engineers to ignore highway engineering issues when undertaking a
speed limit “engineering and traffic investigation” if they want to do so.
296. IDOT’s Speed Policy does not satisfy the road engineering and traffic
investigation requirements of 625 ILCS 5/11-602.
297. IDOT’s Speed Policy has numerous defects that are against engineering
principles, its own Manuals and common sense.
050
298. For example, IDOT’s Speed Policy requires engineers and others to exclude
“access points” after the count reaches 60, at which level IDOT assigns the maximum
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
amount of speed reduction based on the number of access points found.
299. The access point calculation gives more points for a road than for driveways,
varying the number of points assigned depending on unknown factors.
300. WRUD, with three times the number of access points, is given the same speed
reduction as one with sixty despite having three times the number of access points.
301. This calculation violates IDOT’s own Bureau of Design and Environment Manual,
Chapter 46, paragraph 2.03, which states: “Each driveway and cross street reduces
mobility and safety.”
302. IDOT’s Speed Policy requiring its engineers to act as if there is no difference from
the more than 200 Access Conflicts found in WRUD and those with only 60 is also
contrary to common sense.
303. IDOT’S failure to employ proper engineering to Illinois highways to determine
proper speed limits is ultra vires.
304. These failures have allowed IDOT to maintain unlawful speeds on Waukegan
Road in Northbrook and elsewhere throughout the State of Illinois.
305. Defendant must stop these illegal manipulations.
306. A declaration that such manipulations must end, and that the speed limit on
Waukegan Road and elsewhere should depend on proper, fully implemented engineering
for those parts of Waukegan Road not found to be Urban Districts is appropriate. Given
the nature of the problems on WRUD, traffic calming measures should be implemented,
including a road diet.
051
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter an order finding
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that IDOT’s engineering and traffic requirements are contrary to Illinois law, must be
corrected to satisfy Illinois law, and should include traffic calming efforts including a road
diet.
COUNT IX
735 ILCS 5/2-701, ET SEQ.
DECLARATORY JUDGMENT FINDING THAT AN INJUNCTION IS APPROPRIATE
TO STOP IDOT’S ULTRA VIRES ACTIONS REGARDING WRUD
307. Plaintiff brings Count IX for a declaratory judgment under 735 ILCS 5/2-701, et
seq. that IDOT’ actions violate the Equal Protection Clauses of the US and Illinois
Constitutions and 625 ILCS 5/1-214, 5/11-208.1, 11-601, and 11-602, for failing to limit
speed limits in Urban Districts to 30 MPH or less, for failing to use proper engineering
and traffic investigations for WRUD and other Illinois state highways, and for failing to
implement traffic calming measures including a road diet on WRUD.
306 as if fully set forth in Count IX.
309. A declaration that such manipulations must end and that the speed limit on
Waukegan Road and elsewhere should depend on proper, fully implemented engineering
for those parts of Waukegan Road not found to be Urban Districts is appropriate.
PRAYER FOR RELIEF
A. Finding that IDOT has violated the equal protection clause of the Illinois
Constitution;
052

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
to Voltz Road;
Chapel Road; and
E. Finding that IDOT’s engineering and traffic requirements are contrary to Illinois
law and must be corrected to satisfy Illinois law.
Submitted: May 4, 2019
Respectfully Submitted,
______________________
R. Clifford Potter
R. Clifford Potter
Attorney Number: 33212
1130 Waukegan Road
Northbrook, IL 60062
(847) 532-9337
Verification
Under penalties as provided by law pursuant to 735 ILCS 5/1-109, R. Clifford Potter
certifies that the statements set forth herein are true and correct to the best of his
information and belief.
_____________________
053

FILED DATE: 5/6/2019 12:00 AM 2019CH05641

)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 1
IDOT SPEED POLICY
054
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
TRUCKS
WORK I OYER 4 ~ NS _ SPEED
ZONE LIMIT
SPEED
70
1
SPEED
LIMIT
LIMIT
55
45 SCHOOL - - .
PHOTO /
ENFORCED SPEED
$375 FIN E 2LIMOIT -..S-PE-E~D
...
MINIMUM LIMIT
SPEED
LIMIT
ON SCHOOL DAYS
IHEN CHILDR£N
ARE PRESENT
30 20 1
FINES WHEN
CHILDREN
I HIGHER ARE PRESENT
Policy on Establishing and

Posting Speed Limits on the
State Highway System
Effective January 1, 2014
@ Illinois Deparbnent of Transportation

055
POLICY ON ESTABLISHING AND POSTING SPEED LIMITS ON THE
STATE HIGHWAY SYSTEM
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ILLINOIS DEPARTMENT OF TRANSPORTATION -BUREAU OF OPERATIONS
APPLICATION OF POLICY TO CITIES, COUNTIES AND OTHER LOCAL AGENCIES
The Illinois Vehicle Code does not require local agencies .to obtain department approval for speed
zones on roads under their respective jurisdictions. While the procedures contained in this policy
may be used for altering speed timits on any public highway, use of such procedures by local
agencies is not required by statute. tf a 1oca1 agency wishes to ask a district for review of a speed
zone, the district may, of course, do so. However, when responding back to the agency, a
statement should be included indicating that the comments are not to be considered as either
approval or disapproval. Local Agencies should refer to Section 11-604 of the Illinois Vehicle Code
for additional information and specific regulations regarding the alteration of speed limits on local
roads.
GENERAL SPEED LIMITS
Speed limits on highways under the jurisdiction of the department shall be established on the basis
of the latest revisions/editions to Chapter 11 , Article VI of the Illinois Vehicle Code {IVC), the Illinois
Manual on Uniform Traffic Control Devices (IMUTCD), the Standard Specifications for Road and
Bridge Construction, the Highway Standards and this policy. Night speed limits shaff not be used.
A. Statutory Speed Limits
Section 11-601 of the IVC spells out the statutory speed limits in effect in Illinois. These limits
may be enforced without any signing.
Outside Urban Districts
Freeways/Expressways
This category is defined as highways designated by the department which have at least
4 lanes of traffic where the traffic moving in opposite directions is separated by a strip of
ground which is not surfaced or suitable for vehicle traffic. For the purposes of this
policy, this includes all full freeways {Interstate and interstate-type freeways).
-Interstate Highwavs
All vehicles except buses and trucks with gross weights of over 4 tons 70mph
Buses
(Outside of Cook, Dupage, Kane, Lake, McHenry, and Will Counties) 70 mph
(Within Cook, Dupage, Kane, Lake, McHenry, and Will Counties) 65mph
Trucks with gross weights of over 4 tons

(Outside of Cook, Dupage, Kane, Lake, McHenry, and Witt Counties) 70mph
(Within Cook, Dupage, Kane, Lake, McHenry, and Will Counties) 55mph
1
056
Non-Interstate Highways
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Alt vehicles except trucks with gross weights of 4.tons o~ less 65mph
Trucks with gross weights of over 4 tons

(Outside of Cook, Dupage, Kane, Lake, McHenry, and Will Counties) 65 mph
(Within Cook, Dupage, Kane, Lake, McHenry, and Will Counties) 55 mph
This also allows the department to apply these limits to designated sections of rural
expressways with full control of access and at-grade intersections rather than
interchanges. In general, this should only be .done where engineering judgment
indicates such limits may be safely accommodated. Short sections should be avoided.
Conventional Highways
All vehicle types 55mph
Inside Urban Districts (A" vehicfe types)
All streets and highways 30 mph
Alleys 15 mph
"Urban District" is defined in Section 1-214 of the IVC as "The territory contiguous to and
including any street which 1s built up with structures devoted to business, industry or
dwelling houses situated at intervals of less than 100 feet for a distance of a quarter of a
mHe or more." Note that whether the street or highway in question is inside or outside of
the corporate limits of a community is not included in this definition and therefore, is not
applicable to the detennination of where such statutory speed applies. This means that
the statutory speed on an unposted street within the corporate limits of a community but
outside an urban district would be 55 miles per hour. Also note that the structures
referred to in the definition include only those that haye direct vehicular access to the
highway. Structures on both sides of the highway should be counted together in
detenn1ning the interval.
B. Altered Speed Limits
State statutes allow the department to alter certain of the statutory speeds either up or down
(statutory speeds of 55, 65, or 70 miles per hour may only be altered downward). State statutes
and the llttnois Manual on Uniform Trafftc Control Devices fequire that such altered speed ~mits be
based on ".. . an engineefing study that has been performed in accordance with traffic
engineering practices. The engineering study shaH include an analysis of the current speed
distribution of free-flowing vehicles."
The following investigation and selection criteria shall be used to determine altered speed limits on
streets and highways under the jurisdiction of the department. While it is not mandatory that local
agencies use this format and criteria, it is recommended. Regardless of the form the engineering
and traffic investigatfon takes, ~ should be based on valid traffic engineering principals, an analysis
of the speed distribution of free-flowing vehicles, and be well documented .
2
057
Perceived speed enforcement tolerances shall not be taken into account ln the setting of speed
lim•ts.
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Prevailing Speed
The determination of the prevailing speed of free-flowing traffic is the basic step in establishing an
altered speed limit either lower or higher than the statutory limit (statutory speeds of 55, 65, or 70
miles per hour may only be altered downward). This is based on the nationally accepted premise
that a majority of the drivers ·witl drive at a speed which ~Y judge to be safe and proper. · The
prevamng speed is the-computed average of the foUowing ·three sets of data, measured during free-
,flowi~ -·traffic .conditions:
1. EIGHTY-FIFTH PERCENTILE SPEED: The 85th percentile speed is defined as the

speed at or below which 85 percent of the vehicles are traveling. This speed is determined on the
basis of spot speed studies, normally made with a concealed radar or laser speed meter, or
through continuously gathered traffic speed data.
Spot speed studies should be made as close as practicaHo the center of the zone which- i-s, being,
stooled. If the zone is in excess of one mile kl length kl rural areas or 1/2 mile in urban areas,
studies should be made at two or more locations. Care must be exercised to be sure that the data
are collected in such manner and at such times that they are a true indication of normal conditions.
Such conditions normally prevail under good weather conditions, on dry pavement, during daylight
hours, outside of rush periods, and on any day except weekends or holidays. Observations should
not be made Jmmediately foHowing a crash, when traffic is influence by construction or
maintenance operations, or during a per.aiod of greater than normal enforcement. Every effort
shouk:I be made to <;OOCeal the fact that speeds are-being recorded.
For spot speed studies, speeds should be observed for at least 100 passenger cars/vans and
pickup trucks in each lane in each direction. Speeds of vehicles over four tons in size should not
be used in determining altered speed zones. On lower-volume roads where it would be difficult to
sample 100 vehicles in each direction, the study may be terminated after three hours. When traffic
is travelling in pfatoons, tne speed of fhe fead vehicle{s} shoofd be used. Foffowing vehicfes tend to
base their speeds co the lead vehk:te. Use of following vehicles wm tend to bias the recorded
speeds downward. Care sloould also be Saken to avoid, ~ t o g -the speeds of a,~&prop.~
number of high speed vehicles to avoid an upward speed bias.
2. UPPER LIMIT OF THE 10 MILES PER HOUR PACE: The 10 mph pace is defined as
the 10 mph range containing the most vehicles. This is determined on the basis of the spot speed
studies discussed above.
3. AVERAGE TEST RUN SPEED: Average testcfUfl speeds are determined on the basis
of five vehicle rtUns Kl each direction over the ength of the proposed zone. ~t ~ not necessary to
use an unmarked vehicle, however the use of any vehicle which might be mistaken for a law
enforcement vehicle should be avoided. Observations should be made under the same general
conditions noted above for spot speed studies. The prime consideration in use of test runs is to
approximate the median speed. To accomplish this, the driver should try to ''float" in the traffic
stream. On multi-lane roads, the driver should pass as m~ny vehicles as pass the test car. Use of
test run speed is optionaf on rower~vorume roads or when using continuousfygatheredtraffic speed
data and shoukl not be included when. detei:mining. the prevailing speed for ·very shoo zones or for
any specific type of vehicle other than passenger cars/vans.
3
058
The prevailing speed, to the nearest 5 miles per hour, may be used directly as the Altered S_peed
Limit, subject to any further adjustment.rest.00ng·from rev~ing the Anticipated Violatlon Rate as
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
set forth below. However, ~A certain cases, a lower altered ~peed 1imit may be justified on the basis
of supplementary investigations.
Optional Supplementary Investigations
Non-Interstate Highways
The selected Altered Speed Limit may differ from the established prevailing speed (not the
prop.osed posted' ~ by up to 9 mUes pee bour wheA justified by· further: investigation. Such
investigations shall be limited to studying any or all of the following four conditions:
1. HIGH-CRASH LOCATIONS: If the zone being studied contains a portion of a high-crash

segment or contains a high-crash intersection as shown on the most recent 5% report as
distributed by the Bureau of Safety Engineering, the prevailing speed may be reduced by 10%.
2. ACCESS CONTROL: The effect of driveways and other entrances is determined by

using an "access conffiot number." For this purpose, f,ield erwrances or ar~veways to singie-ifamily
dwellings shall have a conflict number of 1. Minor commercial entrances and driveways serving
multi-family residential units and minor street intersections shall have a conflict number of 5. Major
commercial entrances, driveways serving large multi-family developments and major street
intersections shall have a conflict number of 10. If the total access conflict number within a
proposed zone exceeds those shown in. the following table, the prevailing speed may be reduced
by the percentages indicated.
Access Conflicts Percent Reduction

Per Mile in Speed
40 or less 0
41-60 5
61 or more 10
3. PEOESTRfAN ACTJVtTY: Where no sidewalks are prowjed or where sidewalks are

located fl'Tlmediately behind ·Uie cu1'b and the total pedestrian traffic exceeds ten per 'hour for any
three hours within any eight-hour period, the prevailing speed may be reduced by 5 percent.
Pedestrians crossing the route at intersections or established crossing points may be included if
the point of crossing is not controlled by a STOP or YIELD sign on the route in question, or does
not have traffic signals.
4. PARKING: The prevailing speed may be reduced by 5 percent where parking is

penn•tted adjacent to the traffrc tanes.
5. MISCELLANEOUS: Other factors may be incfuded in the investigation based on

engineering judgment. Normally, isolated curves and turns, areas of restricted sight distances,
no-passing zones, etc., should not to be considered as the basis for alteration of speed limits.
To determine the proposed altered speed limit, either use the calculated prevailing speed, or apply
the percentage corrections r-esulting from -any or .aff -of ·tt,e above optional factors to the prevailing
speed, and select the closest -5 mile per hour increment. In no case, however, should the
pro?Qsed a~tered ,Umit differ either u,pward or downward from the prevailing speed by more .than 9
4
059
miles per hour or by more than 20 percent, whichever is Jess. Next, compare the proposed altered
speed limit·to the speeds collected in the spot speed study or from continuous1y gathered traffic
1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
speed data and determine the anticipated vio1ation me. :ff lhe antq>ated vioiation -rate exceeds 50
percent, the proposed attered speed fimtt should be revised in S mile per hour '1ncrements untff the
anticipated violation rate is equal or less than 50 percent. If this results in a proposed altered
speed limit which exceeds a 30 mph statutory speed for the highway in question, either the
statutory speed or the proposed altered speed may be used to set the speed limits. If the speed
selected results in a violation rate greater than 50 percent, the appropriate police agency(ies)
shoufd be notified that extra enforcement efforts may be necessary.
rntte,ences in posted sp)eeds between ~cent allered speed zones sbould not be more tban to
miles per hour.
Interstate Highways
The selected Altered Speed Limit may differ from the established prevailing speed (not the
proposed posted speed} by up to 15 miles per nour or 25 :percent wh1ehever is less when
justified by further mvestjgation. The length of an lnterstate bighway segment to be studied
should 'be 'between 2 and tO mltes iong. Segments whk:n are marked with multiple lnterstate
designations should be studied separately from adjacent single-marked sections. Such
investigations shall be limited to studying any or all of the following conditions:
1. The zone being studied contains a high-crash segment as shown on the most recent
5% report as distributed by the Bureau of Safety Engineering.
2. Access f)Oint density greater than 3 po•ntslmile. The study segment must mcklde a
minimum of 2 interchanges for this requ;rement to be met. Access points incfude arr ramp exits
and entrances for both directions. A standard diamond interchange would consist of 4 access
points. A standard cloverleaf interchange would consist of 8 access points. Rest area and
weigh station exits and entrances should also be included in this calculation . Median
crossovers should not be included. Entrances and exits for collector/distributor roads should
also be included when calculating access point density.
3. Total NJT is above the l~owing minimum values tor the entire length of the study
segment ("# of lanesn includes lanes for both directions). (Collector/distributor roads should be
included when calculating ADT.)
4-lane: 50,000
6-lane: 75.000
84ane: 100,000
10-lane: 125,000
12-1:ane: 150,000
14-lane: 175,000
4. The study segment includes exit ramps with an advisory speed of 30 mph or less and
where traffic routinely slows down on the mainline Interstate while approaching the exit.
5. The study se_gment includes eXJl ramps where traffic routinely queues back onto the
Interstate mainline and other methods of reducing these queues have been implemented
without success.
5
060
6. The study segment includes areas where traffjc routinely travels at less than 45 mph
for at !east 4 hours a day.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
These conditions do not apply to transition zones where the speed limit is decreased because
an Interstate highway is ending and transitioning to a conventional highway or where necessary
to provide an orderly transition to an adjacent Tollway or neighboring state's speed limit. Speed
limits for these transition zones may be decreased based upon engineering judgment. Altered
speed limits of 50 or 45 mph based on the conditions above may be transitioned in increments
of 10 to 15 mph from a statutory 70 mph speed ttmit. Afrf transmon zone should be at least 1/2
mile in length.
To determine the proposed altered speed limit, either use the calculated prevailing speed, or
apply adjustment factors resulting from any or all of the above conditions to the prevailing
speed , and select the closest 5 mile per hour increment. In no case , however, should the
proposed altered speed limit differ either upward or downward from the prevailing speed by
more than 15 miles per hour or by more than 25 percent, whichever is less. Interstate speed
limits shaU not be altered .above the maximum statutory .speed limit and shouJd not be altered
below 45 mph.
Adjustment factors for Interstate Highways

If conditions 1 Q! 2 are met, a 0.95 adjustment factor may be applied
If conditions 1 and 2 are met, a 0.90 adjustment factor may be applied
- A 0.975 adjustment factor may be applied for each of conditions 3 through 6 that are met
Example:
Prevaiting speed.= 68 mph
Conditions 1 and 2 are met: (0.90) adjustment factor
Conditions 3, 5, and 6 are met: (0.975)*(0.975)*(0.975) adjustment factor
68*(0.90)*(0.975)*(0.975)*(0.975) = 56 .7
Round to 55 mph (within 15 mph and 25% of 68 mph)
C. Posting of General Speed Limits
Speed Reduction Signs
A Speed Reduction sign (W3-5) shall be erected in advance of any non-work zone speed zone
that is 10 miles per hour or more under the passenger car limit in a preceding statutory or
altered limit of 45 miles per hour or more and should be erected at other locations where
engineering judgment indicates the need. It shalr be pfaced approximatefy 500 to 600 feet in
advance of the lower speed zone and shalt always be followed by a basic speed limit sign erected
at the beginning of the zone.
On divided and one-way facilities having two or more lanes in one direction, the Speed Reduction
signs, where used, and the first basic speed limit sign for the altered speed zone, shall be installed
on both sides of the roadway except in situations where insufficient room exists in a median. Red
1.8-inch metal r.etr-oreflectorized "flags" sttan be installed on the Speed Reduction signs, If used,
preceding any transition from a 65 or 70 mlles per hour zone to a Jower speed zone. These red
~ags" shall also :be installed on the fa-st speed firrnt signs for a 1owered speed zone from a
preceding 65 or 70 miles per hour zone.
6
061
When speed zones on rural highways extend only through signalized intersections, speed limit
signs for the altered zones shalf be instaUed at least 1,000 feet prior to the intersections on both
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
sides of the roadway except in srtuatroos where insufficient room exists in a median. Normally,
such- aftered zones shoutd be terminated approximately 500 feet beyonct the intersection.
Speed Limit Signs
Speed limit signs shall be posted at points of entry to the state even where the preceding speed
limit in the adjacent state is the same. The signs should be placed as close to the state line as
posstble. On conventional rur.al .hjg"hways, speed Jimlt signs shot.Hd also be posted after major
tlighway mtersections, and at such othler 'locations as .necessary to ensure ;tt)at there Js at ,least one
sign every 10 miles. On Interstate highways and other full freeways, speed limit signs should be
placed following the entrance ramps from all except very closely spaced interchanges, and at such
other locations as necessary to ensure that there is at least one sign every 1O miles.
The prohibition on the use of electronic speed detection devices within 500 feet beyond certain
speed limit signs in the direction of traveJ (Section 11-602 of the JVC} shall not be taken into
account in the placement ot speed ftmit signs.
The following spacings for speed limit signs are recommended in altered speed zones and for 30
mph zones in urban areas. All speed zones, either altered or statutory, shall be posted on state
highways.
Posted Speed Recommended Sign Spacing
30 mph or ~ess 660 ff .to 1,320 ft

(2 to 4 blocks)
35 or40 mph 990 ft to 1,980 ft

(3 to 6 blocks)
45 or 50mph 1,320 ft to 2,640 ft

(4 to 8 blocks)
55 mph or above 2 to 10 miles
Some speed limit signs for freeways/expressways where the speed limit differs between trucks
over 4 tons and all other vehicles shall include an additional Trucks Over 4 Tons' R2-1109 plaque.
This plaque shall be installed above the first 55 mph speed limit sign entering the dual speed zone
and the fust speed limit sign exiting the dual speed zone. Red 18-inch metal retroreflectorized
flags shall also be installed on the first 55 mph speed limit sign entering a dual speed zone.
Minimum Speed Limit Signs
A MINIMUM 45 mph speed plaque (R2-1101) shall be placed below each basic 60, 65, or 70 mph
speed limit sign (R2-1) for fully access-controlled freeways only. It may be omitted where closely
spaced interchanges or volume/capacity restraints make compliance with a 45 mph minimum
speed limit impractical. A minimum speed shalt not be used with 55 mph or lower speed limits.
062
SCHOOL SPEED LIMITS
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
School speed ·limits -0n 'highways 'Under the Jurlsdiction.of the department shall be estabUshed on
the basis of Article V1 of the fflinois Vehicle Code (IVC), Part 7 of tt,e ttfino,s Manual on Uniform
Traffic Control Devices (IMUTCD) and this policy.
Section 11-605 of the IVC allows establishment of 20 miles-per-hour speed limits on streets and
highways passing schools or upon any street or highway where children pass going to and from
school. Such established limit is to be in effect "On a school day when school children are present
and so ctose thereto that a potentiaf hazard exists because of the close proximity of the motorized
trafflC..." IC further defines sc!Clooli d9Ys as l)eginning a1i: 7 a.m. and endfng, al! 4' p.m. Such a zone
may be established for public, private and religious nursery, primary or secondary schools.
An engineering and traffic investigation shall be conducted to determine whether or not a school
speed zone is warranted. The investigation shall consider such factors as the existing traffic
control, whether school crosswalks are present or not, the type, character, volume and crash
history of vehicuJar traffic, and the ages and numbers of schoolchildren likely to be present. It shall
also consider where the chi1dr8A WOlf1d be tooated Jin l81a'oon lo 1he lraffic.
Speed zones should be limited to those locations where school buildings or grounds devoted
primarily to normal school day activities are adjacent to the highway or where groups of children
cross the highway on their way to and from a school. Areas devoted primarily to athletic or other
extracurricular activities should not be zoned.
The limits of school speed ZOf\8$ 5hould be determined based upon where children are likely to
be present and not based upon the limits of .the school property. There are situations, primarily
in rur:at areas, where the sct.loo.f-ownect· proper.ty lme is some distance from, the actual portion- of
the property occupied by the school and there are no children walking or present along that
portion of the property. Establishing a 20 mile-per-hour school speed limit based solely on the
location of the property line would be inappropriate. Conversely, it might be appropriate to
impose a 20 mile-per-hour school speed limit some distance ahead of the property line where
children walk close to the highway on their way to and from school and such path is part of a
planned school walk route.
Speed zones shooid .not be established for crossings where schoolchildren are protected by
devices such as stop signs or traffic signals. An exception may be made when the speed zone
serves to protect children walking on or immediately adjacent to the roadway in the school area.
Speed zones should not be established when the school or school grounds are completely isolated
from the highway by means of a fence or other barrier, and no access to the highway is provided.
They should also not be established for crossing where an underpass or overpass is provided or
for school entrances used for buses or private vehicles carrying childfen to and from school.
The beginning of a schoor speed' zone sk'louldl l!:Je marked with a ~ speeci limit 20 mph sign
(S4-I100 or S4-I101) with a FINES HIGHER sign (R2-6P) mounted underneath. The end of a
school speed zone should be marked with the ~ppropriate standard speed limit sign (R2-1) and an
END SCHOOL ZONE sign (S5-2) mounted underneath.
a
063
WORK ZONE SPEED LIMITS
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
A.. Altered Speed· Lim its
• All roadway types with no lane closure.
The existing speed limit should not be lowered when there is no lane closure. A work
zone speed limit which matches the existing regulatory speed limit may be established
except for mter.mittent/moving operations and wor1( aiong .ramps.
tf a JusWication from Section C iis met.and cannot .be «nmedcately corrected, a reduction
of up to10 mph should be considered for roadways with a speed limit of 65 mph or less.
A reduction of 15 mph should be considered for roadways with a speed limit of 70 mph.
This reduction shall be based on engineering judgment and shall be approved by the
District Operations Engineer.
I • Existing 70, 65, or 60 mph - Multilane: Speed Limit Reduction to 55 mph
55 mph Work Zone Speed Limit signs (see Art. 701. 14(1)); of the Standard. Specifications
for Road and Bridge Construction) shafl be used to reduce posted speed limits from 70,
65, or 60 mph to 55 mph in construction work zones with lane closures or crossovers as
shown on the Highway Standards or as noted in the traffic control plans. Reduced
Speed Zone Ahead Signs (>N3-5) shall be posted 500 ft. in advance of the first work
zone speed limit signs for roadways with posted speed limits of 70 mph. For this
reqtitrament to ·be added to an ongoing contract, '.it must be approved ~Y .t he District
~ o n s Engineer. Wor:k Zone S.peed Limn signs may also be used to reduce the
existir:wg speed ·tmit to 55 .mph ·if e~ineerir,g .juctgmerrt indicates the raduced speeds are
necessary (See Section C}. Approval of the District Operations Engineer is required.
These signs shall be removed or covered when the reduced speed limit is not
applicable.
l• Existing 70, 65, or 60 mph - Multilane: Speed Limit Reduction to 45 mph When Workers are
Present
45 mph Work Zone Speed Limit signs (see Art. 701.14(b) of the Standard Specifications
for Road and Bridge Construction) within the lane closure shall be used when workers
are present in the closed lane adjacent to traffic and are not protected by temporary
concrete barrier. This sign may be used in conjunction with other Work Zone Speed
signs to drop the 55 mph Work Zone Speed Limit to 45 mph.
If condmons that warrant these signs develop during construction, the signs may be
added ;to ;the contract upon approval of the DJstrJct Operatlons,Eng,ineer (See Section C).
These signs shall be utilized as indicated in the Highway Standards and as noted by the
designer in the traffic control plans. The signs shall be covered, turned or removed when
workers are no longer present.
9
064
• Existing 45 - 55 mph - Multilane: Work Zone Speed Limit 45 established
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Work Zone Speed Umit signs for existing multilane 45 to 55 mph speed limits shaH be as
shown on the Highway Standards and as noted mthe traffic control p1ans. The signing
changes an existing 45 mph speed limit to a 45 mph work zone speed limit. A reduction
in the speed limit beyond 10 mph is not recommended and design changes should be
considered that will allow traffic to safely move at 45 mph.
• No Speed Limit Reduction - Multilane with speed limit below 45 mph and lane closure
The existing speed' fimit shoutd not be lowered. A work zone speecl limit which- matcnes
the existing regulatory speed limit may be estabfished except for intermittent/moving
operations with a moving lane closure.
If a justification from Section C is met and cannot be immediately corrected, a reduction

of up to 10 mph should be considered. This reduction shall be based on engineering
judgment and shall be approved .by the District Operations Engineer.
• No Speed Lmm Heduciioo - Aft 2--Lane roadways wnn 'lane closure

The existing speed limit should not be lowered and a work zone speed limit should not
be established.
If a justification from Section C is met and cannot be immediately corrected, a reduction

of up to 10 mph should be considered. This reduction shaft be based on engineering
judgment and shatf be approved by the District Operations Engineer.
B. Increased Fines in Work Zones
The applicable highway construction or maintenance speed limit fines are specified in Section
11-605.1 of the IVC.
The work zone must be posted according to the requirements for Work Zone Speed limit signs.
For the 1ncreased fines to be enforceable, the Minimum Fine Sign, and the WORK ZONE &gn
must be present as shown in the applicable Highway Standards.
C. Justifications for Work Zone Speed Limit Reductions
The following may be additional reasons for reducing an existing speed limit in a work zone or
for estabfishing a work zone speed Nm-it in excess of tO mph befow the existtng, speed limit.
This reduction should be based on engineering judgment, documented, and approved by the
District Operations Eng,if:lee~.
• Narrow lane width of 10 feet or less

• Drop-offs
• Temporary road alignment where a design for higher speed operation is not
feasible due to space requirements or other factors
• lnadequate-sight distanre
10
065
D. Posting of Work Zone Speed Limit Signs
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Work Zone Speed Limit Signs shaff be posted according to Article 701'~t4(b) of ttle Standard.
Specificatrons for Road and Brrdge Construction, the appricabte Highway Standards, and as
shown on the design plans. When Work Zone Speed Limit Signs which match the existing
regulatory speed limit are installed, the permanent speed limit signs shall be removed or
covered. The following reasons should be considered when determining whether to install
optional work zone speed limit signs where the work zone speed limit matches the existing
regulatory speed limit,
• Duraion of wOl'lc
• Ease of installation of work zone speed limit signs and removal or covering of
existing speed limit signs
• If there is adequate space to install signs
• If there is adequate sight distance
• If installing optional work zone speed limit signs may put workers in undue
danger from trafftc
MISCELLANEOUS SPEED POLICIES
A. Blanket Speed Limit Signs
Posting of _signs indicating general municipal speed Jimits, such as "SPEED LIMIT 25 ON VILLAGE
STREETS," shafl not be used on .state hghways. Section 11-604 of the NC requires that speed
fimit signs be '. ptaoed "...at \tie proper ;place or along the proper :part .or zone of the highway or
streee' The Office of Chief Counsel has detennined that this requires each individual altered
speed zone be signed.
B. Radar Warning Signs
SPEED RADAR TIMED, or other similar signs, shall not be used on state highways. An Illinois
Attorney Generars Opjnion {1966-196) stated t~at sucn signs were not necessa,y for enforcement.
C. Aerial Speed Check Markings
Where requested by the Illinois State Police, aerial speed check markings on state highways may
be placed in accordance with the guidelines contained in Section 7-401.21 of the Bureau of
Operations Traffic Policies and Procedures Manual.
D. Design, Posted, and Operating Speeds
To prevent potential safety issues, the design speed selected to determine the design features of a
roadway should equal or exceed the anticipated posted speed after construction as determined by
the requirements of this policy. The designer should coordinate the design speed selection with
the District Bureau of Operations anticipated posted speed limit selection. If the proposed design
speed will be less than the anticipated posted speed, the designer must choose one of the
foltowklg approaches:
11
066
- Seek a design exception
- Increase the design speed to equa1 the .anticipated posted speed
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
- Post lhe 1 ) ~ with a legal speed fimit equal to the design ~peed
(The fegai speed timit shaft be determfned in accordance wlth:
Section 625 ILCS 5/11-602 of the Illinois Vehicle Code
Section 23 CFR 655 of the US Code of Federal Regulations
The requirements of this policy)
The designer should avoid artificiaUy selecting a design speed low enough to eliminate any design
exceptions. For example. if lDOT criteria yield a design speed of 60 mph and one or more
geometric features are adequate ontf for 55 mph, the design speed should oe 60 mptn aoo not 55
mph. The designer wilt then be required to seek design exceptions for 55 mph geometric features.
Curbed Sections
Sections with continuous barrier curbs at or near the edge of pavement should be avoided in
areas where operating speeds can be expected to be greater than 45 mph. However, where a
speed study justifies a speed fimlt of SQ mph or greater, 1he JPOSted ·.um1t may be reduced to 45 mph
upon the wrfflen approva1 df ff1e Oistoot Operations Engineer. rlf tbe curbed section ,is short, such
as with channelizing in conjunction with a freeway interchange, the operating speed should be
used.
E. Two-Way Left Turn Lanes
Two-way left turn lanes should be avoided in areas where operating speeds can be expected to
be greater than 45 mph. However. where a speed study justffies a speed.. limil of 50 mph or
greater, the posted fimit may be reduced to 45 mph upon Ile wntten approval of the District
Operations Engineer.
F. Park Zone Speed Limits
Park Zone speed limits on roads under the jurisdiction of local agencies may be established on the
basis of Section 11-605.3 of the IVC and part 2 of the JUinois Manual on Uniform Traffic Control
Devices {1MUTco,.
Section 11-605.3 of the IVC allows local agencies to establish Park Zones and Park Zone
Speed Limits by ordinance or resolution on streets and highways under their jurisdictions which
abut parks. It does not allow the posting of a 20 mph Park Zone Speed Limit along streets or
roads under the jurisdiction of the Illinois Department of Transportation.
A reduction in the speed limit along an abutting street under the jurisdiction of the department
could be estabfished in accordance with Section 11-602 of the ~VC where warranted by a speed
study. However. such a r:edt1ction in the speed fifmt wouJd be signed\ as a normal speed limit
and not as a "park zone speed-•
If requested by local agencies, districts may post Illinois Standard W15-l100 PARK ZONE signs
on abutting streets and highways under the jurisdiction of the department if the local agency has
established and signed a park zone. These signs may be installed regardless of whether a
~ zone ~eed .fflfflt" has been estabtished or not
12
067
SPOT SPEED STUDY
_DIST:,,..,._ CITY/LOCATION: ......._ _ _ __ _ ___ ROUTE: _ _ _ _ _ _ _ DATE: _ _____.__ DAY:_
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
CHECK NO. RECORDER

FM:
TO:
_,.
HOURS
.-M
W:ATH~ SURFACE _FT.Ml. METl!RON TRAFFIC
W&T
DAMP
86TH 'UPPER LIMIT POSTEDUMfT VIOIATION
EWNSOF EWNS CHECKED: PERCNTLE 10MPHPACE
ttlOB EB WB
MPH RAlE
DRY NB SB
!JJ e~ e I!:~ iii! l::i ~ ~ ~ ~ ~ ~ ~ ~ ~..., 1G IUI ?HJ 2~

. '
~
"- ~- ·-~ ~ ~ !!!J:3 ~ t lt ~ ~ ~ ~ It ~ ~I!: ~~ ~ ~ ~~ it: ~!::t w,-.;
Ott> ..., a, ~~ ~~ ~n~
JS! NN
~- ....,, -
.
·-
__ ._ -- - ,__
.....
-- .. - - ...... -- ---
<,J
-- ---
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~
·-
--
- --
,.
_.....
--
'·"'
•- t - ....
,- '
--
- --~-
·- t- 1--1- --
068
ESTABLISHMENT OF SPEED ZONE
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
DISTRICT _ __
ROUTE: _ _ _ _ _ _ _ _ FROM: _ _ _ _ _ _ _ _ _ _ _ _ _ __
TO: _ _ _ _ _ _ _ _ _ _ _ _ _ _ LENGTH:
----------
CITY: _ _ _ _ _ _ _ _ _ _ _ COUNTY:
------------
I SPOT SPEED STUDIES (Attached) v ACCESS CONFLICTS
CHECK NO. 85TH o/o UPPER LIMIT RESIDENTIAL DRJVES: X 1t = __

10MPH PACE SMALL BUSINESS ORfVES: _ _ X 5 = _ _
LARGE BUSINESS DRIVES: X10 =--
ACCESS CONFLICT NO. TOTAL·.__ _ _ __
STUDY LENGTH: _ _ = _ _ _ _ __
(MILES) CONFLICTS/ MILE
II TEST RUNS VI MISC. FACTORS

RUN NO. AVG . DIRECTION
SPEED PEDESTRIAN VOLUME: _ _ _ _ _ __
1 HIGH-CRASH LOCATION: _ _ YES _ _ NO
2 PARKING PERMITTED: _ _ YES NO
3
4
5
Ill PREVAILING SPEED VII PREVAILING SPEED ADJUSTMENT

DRIVEWAY ADJUSTMENT: %
55TH % AVG. : MPH PEDESTRIAN ADJUSTMENT: %
UPPER LIMIT OF CRASH ADJUSTMENT: %
1-0 MPH PACE: ·AiMWt TOJ AL {MAX 20%): %
TEST RUN AVE. : MPH
PREVAILING SPEED: MPH MPH X %=
(Prevailing Speed) (adjust.) (Max. 9 MPH)
ADJUSTED PREVAILING SPEED:
rv EXtSTJHG SPEED LIMIT VIII REVISED SPEED LIMIT

' RECOMMENDED SPEED UMIT: MPH ·
ZONE BEING STUDIED: MPH ANTICIPATED VIOLATION RATE: %
VIOLATION RATE: %
ADJACENT ZONE N or W: MPH RECOMMENDED BY:
LENGTH: MILES DATE:
ADJACENT ZONE S or E: MPH APPROVED BY:
lENGTtt M~LES DATE:
14
069
45 MPH . EXISTING SPEED UMtT 40 MPH EXISTING ~ b LIMIT 40 MPH
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
(I, • LANE - NO MEDIAN - SOE

~ W~AL-:-
k.5- --=-
NO=P:= :'lit
AJ;VeRRt> - Il.33
PARIC WOOD RR OAK MAPLE

.....
(11
LARGE BUSINESS
SMALL BUS!Nf;SS
-~ z
RESIDENCE CONDITION DIAGRAM
District 7
TRAFFIC SIG~L Illinois 33 River Road
First Ave to Elm Road
.. RADAR LOCATIO.N Frostville, Damon County
.M/7\ LOCATION/1:JJ:R.f;CTION
~ OF ANY PHOTOS
070
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

GROUP EXHIBIT 2
REPRESENTATIVE GABEL
IDOT CORRESPONDENCE
071
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
October 9t 2014
Mr. Cory Jucius,

IDOT, Speed Study Analysis Dept.
201 W. Center Court
Schaumburg, IL 60196-1096
Dear Mr. Jucius,
I have received numerous letters from my constituents regarding the speed limit on
Waukegan road in what is considered the downtown Northbrook area.
I have met with the Village of ~orthbrook President, Village Manager and the Public
Worlai department to discms 'this matter. The Vdlage i~ totatly supportive of reducing the
speed limit on that stretch of road between Dundee and Walters roads.
I urge to you reconsider your decision, and reduce the speed to 35 or preferably 30 MPH
for that stretch of road in order to be more in line with the rest of Waukegan road that
goes through the downtown areas of Deerfield and Glenview.
I also wanted to discuss another matter witb yon. We have a constiaJem-t who lives oo-
Shermer road between Dundee and Waukegan. He told me that he has talked to IOOT
about putting safety crosswalks at the Lee and Hillside intersections near Shermer and
Waukegan. I wanted to get an update on where we are with that proposal.
Please feel free to co.ntact me to discltSS ·thi~ further.
Thank you for your assistance with these constituent issues,
RobynOabel
State Representative - 18th District
072
IIHnois Department of 1tansportation
Division of Highways / Region 1 / District 1
201 West Center Court I Schaumburg, llfinois 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
October 24, 2014
ST 3.3 (C) IL 43 (Waukegan Road) Speed Studies

RT 1 (C) Shermer Road
The Honorable Robyn Gabel

lllioois State Representative
Eighteenth Representative Distrjct
820 Davis Street
Suite 103
Evanston, IL 60201
Dear Representative Gabel:
We nave receivecfyour October 9. 2014 letter regardfng:your constituent's

requests to reduce the speed limit on Wa:ukegan Road trom. the currently
posted 40 mph lrmit and the proposed crosswatks on Shermer Road.
The Illinois Vehicle Code requires that an engineering and traffic investigation
be used as the basis for posting any speed limit other than those specified by
statute. The purpose of the study is to determine the speed limit that is
consistent with motorist safety and 'INlth the safety of other necessary actlvttles
:a-long the highway.
A speed study was completed on IL 43 (Waukegan Road) from south of Voltz

Road to Illinois 68 (Dundee Road) last November where the currently posted
speed limit was found to be proper and consistent with safe vehicular travel.
However, the Department has scheduled a new speed study in which traffic
. obsetvations wrn be made to provide ililformation on the prevailing speed of the
vehicles travelTng on fftinois 43 along the subject lfmits. The appropriate speed
limit( s) will then be-determined by considering additionat factors·such as
· pedestrian activity, the number of intersecting streets and driveways, parking
conditions, the most recent accident experience available to the Department,
and speed limits posted on adjacent sections
.
of highway.
.
th4s study to be oom-?fe,ted oy ~e end of November -Md we wi#

We antictpate _
·let you know the ·results of our investigation at that time. ·
In regards to the proposed crosswalks along Shermer Road between Dundee

and Waukegan Roads, the Village of Northbrook needs to complete their
_ _________ ____ ·····- ••--·-- -- _sj_dewaJk ..s_Y-ste.m_along Shermer.Road. In addition, tbe_Villag.a.wauld be._ ·-· ...
· responsible for securing a permit from the Illinois Department of Transportation
(IDOT) to in.stall ADA compliant ramps and pads at the proposed crossings and
they \NOUld also be responsible for painting·and maintaining the. proposed
crosswalk makings, .
073
Representative Gabel
October 24, 2014
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Pa~e Two
Once these improvements are made, IDOT would install and maintain any
supplemental pedestrian crossing warning signs. The Village of Northbrook
should contact Mr. Jonathan Karabowicz, Area Permits Engineer, at (847) 705-
4149 to fnltiate the permit process,.
If you have any questions or require additional information,, please contact Mr.
Hussain Mesyef, Arterial Traffic Operations Engineer, at (847) 705-4138.
Very truly yours,
/l/ ~
Xcntmann, P.E.
Deputy Director of Highways
Region One Engineer
074
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 3
WRUD SRA REPORT (EXCERPT)
075
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
trategic
egional
rteria/
Illinois Route 43
(Harlem Avenue I Waukegan Road)
from US Route 30 (Lincoln Highway) to lake-Cook Road
FINAL REPORT
.Volume
. rI
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Operation
Green Light
Illinois Department of TransP.ortation
Apnl, 19.9 6
076
FOREWORD
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Illinois Route 43 is a Strategic Regional Arterial from US Route 30

(Lincoln Highway) in Will County to Lake-Cook Road, with a project
omission in the central section of the corridor. Due to the presence of
on-street parking. narrow right..of-way. and intense land use, the area
bounded by North Avenue and Irving Park Road has been removed from
the Strategic Regional Arterial System.
This Strategic Regional Arterial (SRA) Report has been prepared for the
Illinois Department of Transportation and the SRA Subcommittee of the
Chicago Area Transportation Study by Meridian Engineers & Planners.
Inc ..
The Illinois Route 43 SRA is intended to function as part of a regional
arterial system. It along with other SRA routes and the regional ex-
pressway and transit systems, will provide a network to carry high-
volumes of long-distance traffic. This report is one element ofa long-
range plan for all routes in the SRA network. Together. the route studies
constitute a comprehensive, coordinated plan for the entire SRA net-
work.
Included in this report are: a description of the SRA study objectives
and process; a detailed explanation and analysis of the existing route
conditions; recommendations for improvements; and documentation of
the process including comments received.
Information regarding the study and this report are available from the
IDinois Department of Transportation, through the SRA Project
Manager - Mr. Rich Starr, 847/705-4095.
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=o=u=t-e___4=3===============================::J~a &
W - DINflTYIIIIT OF TIUl,NPOlrfATIDIII
7
FOREWORD
077
4.15 Segment 15: Willow Road to Walten Avenue
Location
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
IDinois Route 43 (Waukegan Road) Segment 15 extends from

Willow Road to Walters Avenue (See Figure 4.1 . l ). This segment
is approximately 1.8 miles in length and is located in Northbrook
and unincorporated Cook County.
Existing Facility Characteristics

The existing facility characteristics for this segment of IDinois
Route 43 are shown on Exhibits Il..L 43-22a through 23a.
Right-of-Way. The existing right-of-way varies in this segment.
At Willow Road the right-of-way is 140 ft. and it narrows down to
66 ft. at Voltz Road. There are no areas where the existing width
is the desirable 1 SO ft. for a suburban segment.
Roadway Characteristics. The pavement width in this segment

varies from 52 ft. to 64 ft. The pavement cross section includes
two through lanes in each direction with a flush or raised median
that varies from 4 ft. to 16 ft. Sidewalk and gravel shoulders are
used throughout portions of this segment. The roadway is
widened at Willow Road for left turns.
Traffic Control/Intersection Details. There are three signalized

intersections in this segment:
Willow Road Three Lakes Drive TechnyRoad
Throughout this segment Illinois Route 43 signal approach laneage

includes two through lanes in each direction with left tum lanes
provided at Willow Road and southbound Three Lakes Drive. A
right tum lane is provided at northbound Three Lakes Drive and
northbound Willow Road. Between signals left turns are allowed
at all cross street and driveway locations. The only major
intersection in this segment is Willow Road. It is shown in Figure
4.15.2.
Illinois Route 43
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT
=
c==========================================::1c=..J~d;... ~
~
Ofl'AAllllilff Of' '!M.-oRTATION
7
078
Figure 4.15.2: Existing Intersection Configuration
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Jll~ ~
~ ... ·····t ·· · · ··-r-= ·
WllkM Rd.
q nw
Structures. There is one structure in this segment.
Table 4.15.1: Existing Structure List
IDOT Facility Canied I Feature Crossed Width Length Horizontal Vertical
Structure (feet) (feet) Clearance Clearance
Number (feet) (feet)
016-0306 ILL Route 43 (Waukegan Rd.)/ 46.0 135.0 NIA NIA
C&NWRR
Transit. There is no public transit service existing in this

segment.
Existing Environmental Characteristics
The existing environmental characteristics for Segment 15 of
Illinois Route 43 are shown on Exhibits ll.L 43-22a through 23a.
Streams/Wetlands/Floodplains. The West Fork of the North
Branch of the Chicago River is located 1200 ft. west of the route
with its floodplain coming within 400 ft. of the roadway. There
are small wetlands within 700 ft. of Illinois Route 43 between
Willow Road and Techny Road.
South of the C&NW Railroad near St. Mary' s Cemetery is a small
wetland within 200 ft. of the roadway.
Historical Significance. No sites of documented historical
significance are located along this segment.
Hazardous Waste/LUST Sites. A landf'tll is located across from
Three Lakes Drive along the route. A leaking underground storage
site has been reported along the route.
• Missionary Sisters ofHoly Spirit, 2600 Waukegan Road,
Techny
c'_1_1i_n__o-:_i_s=R
=o=u=t-e___43================================::::;~i; &
ILUN(a -IITYlillT OI' TA.uHl•ORTA1101f
1
079
Prime Farmland. No prime farmland exists along this segment.
Threatened and Endangered Species. No threatened or
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
endangered species are known to exist along this segment.

E:xisting Land Use/Development Characteristics
Type and Intensity of Development. Kraft Foods office complex
is at the northeast comer of Willow Road and Illinois Route 43.
The land uses northwest of the Kraft complex are open space and
landfill. St..Mary's Infirmary and Cemetery are north ofTechny
Road. Meadow Hill Park is adjacent to Illinois Route 43 southwest
of Walters Avenue.
Development Access and Constraints. There are no unusual
constraints to development in this segment.
Future Development. Exhibit ILL 43-22a depicts planned land
uses based on the Techny Master Plan (11/15/88). The plans call
for specific parcels to be developed for mixed use, office~ open
space and residential use as shown on the exhibit.
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4-3
____
-:_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_ _-_-_--,_ ~ a ; • • ,
- _-
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT ~ Olf'AlffllUf'f °" TAANPOIITAflON
080
Recommended Improvements
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Improvements, which are consistent with SRA policy, have been

developed by evaluating numerous factors including the year 2010
projected travel demand, the existing roadway characteristics, and
the character of development along the route. Recommended
improvemen~ for the 2010 timeframe, are shown on Exhibit ll.L
43-22b through 23b and summarized in Table 4 . 1S.3.
Roadway. The recommended roadway configuration varies

throughout the segment. From Willow Road to Voltz Road, the
proposed 120 ft. to 140 ft. right-of-way provides for three 12 ft.
through lanes in each direction with an 18 ft. raised median and
parkways vmying from 1S ft. to 27 ft. with curb and gutter. From
Voltz Road to Walters Avenue, the 90 ft. to 120 ft. right-of-way
provides for two 12 ft. through lane in each direction with an 18 ft.
raised median and parkways varying from 12 ft. to 17 ft. with curb
and gutter. Sidewalks are recommended throughout this segment.
•
120'·140' P~ R.0.W.
10CM40' Existing R.O.W.
.
!
15'-25' t
!
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f S'-25'
·1·
36'
,C
18'
•1• ·r38'
·1· •1
f•
IL
lj 11
l:1 11 f
IL
Propoaed Crou lecllon
120' P ror,osed R.O.W.

88'-100' EidatlnQ R.O .W.
2r 1• 24' 18' 2•· · • 2r
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Proposed Cn,sa Seclloll
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CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT W!loa DIPt.llTUINT °' TM-,..TATION
081
7
• 90'·100' Prpposed R.O.W.

68'-100' Ewi.t!ng R.O.W. •
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
12":1r 2•' 1a· 2•· 1r:~r

. T 'I' T l .
I l1
Table 4.15.3 Summary of Recommended Improvements
R.ccommendation
l. Right-of-Way Width 120 ft.-140 ft. right-of-way from Willow Rd. to Techny Rd.
120 ft. right-of-way &om Tcchny Rd. to Voltz Rd.
90 ft.-100 ft. riRht-of-wav from Voltz Rd. to Walters Ave.
2. Level of Service LOS EtoF
3. Number and Width of Three 12 ft. lanes in each direction fiom Willow Rd. to Tocbny Rd.
Tbrou2h Lanes Two 12 ft. lanes in eadl direction from Tcchnv Rd. to Walters Ave.
4. Median Width and Type 18 ft. raised median.
5. Padtways/S.idewalks/ IS ft.-25 ft. parkways from Willow Rd. to Tedmy Rd.
Drainage Ditch 27 ft. parkways from Tecbny Rd. to Voltz Rd.
12 ft.-17 ft. parkways from Voltz Rd. to Walters Ave.
6. Signali7.ed Intersections There is one major signalized intersection at Willow Rd.
-Major Provide signals south of Tccbny Rd. and Voltz Rd.. when warranted.
• Other
7. Parking NIA
8. Curb Cut Access Provide median breaks at 1/4 mile soacirul.
9. Transit Provide signal prccmplion for buses. Provide directional signs to
nearby transit stations.
10. Pedestrian/Bicycle Provide pedestrian access to Northbrook Junior High School,
Facility Divine World Mission Center.
11. Loading Off street only.
12. Miscellaneous N/A
Traffic Control/Intersection Conf"aguration. All signalized

intersections in this segment should be interconnected with actuated
left tum phases. Dual left tum lanes and single right turn lanes are
proposed at all approaches of the Willow Road intersection. A
single left tum lane is proposed at northbound approach at Techny
.
Illinois Route 43 (c:6oYD=
c=======================================::::=Jc=.,.)~as.
• IUJNOI& DIPMllNUIT a. l'IUIIN~ATION 7
082
Road. A new signal with left tum lanes is proposed south of
Techny Road to access new development in that area and at Voltz
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Road when warranted. The expected level of service is "E" to "F."

Parking & Access. No on-street parking is recommended for this
segment. Left tum access is provided at existing and proposed
signal locations and median breaks at 1/4 mile spacing.
Remaining access locations are limited to a right in/right out
configuration. A median break is proposed at Maple Street to
serve the Northbrook Junior High School, Meadowhill Aquatic
Center and Velodrome, and Ed Rudolph Meadowhill Park.
Structures. There are no structure modifications in this segment.
Transit Facilities. Space should be reserved for bus turnouts at
1/2 mile intervals, consistent with SRA and Pace guidelines.
Precise locations should be coordinated with plans for
development of the Techny properties to provide maximum
convenience.
It is possible that a new commuter station would be built to serve
the Techny developments. Access to the rail line should,
accordingly, be planned from Illinois Route 43 .
Signals should be equipped for the eventuality of bus signal pre-
emption.
Pedestrian/Bicycie Facilities. Pedestrian crossings and bicycle
linkages should be coordinated with the expansion of the Techny
development and provided to the Northbrook Junior High School.
Other Recommendations. There are no other unique
recommendations for this segment.
Short Term/Low-Cost Improvements
Improvements, which are consistent with SRA policy. and are
short term (and or low-cost) are recommended for short tenn·
( 1-5 years) implementation. There are no short term
improvements reeommended in this segment.
Right-of-Way
Toe recommended right-of-way for this segment varies from 90 ft.
to 140 ft. which will require takes varying from 20 ft. to 54 ft. The
takes will be centered the entire length of the segment.
Illinois Route 43 {c::SoY7l=

c===========================================:Jc=..}~m.-
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT ~ IISPARt\11"1' CII' -•l'OIITATION 7
083
9
Potential Environmental Concerns
Although much of the land is currently vacan~ the planned Techny

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Development of residential, commercial. office, and mixed use

will be constructed in the near future. Expansion of
the right-of-way to 140 ft. may necessitate purchase of properties
soon to be developed, in addition to those fronting the roadway
south ofWalters Road. The affected properties include a
municipal landfill and park.
Cost Estimate
The cost estimate shown in Table 4.15.S for Segment 1S is

$9,070,000.
Table 4.15.5: Cost Estimate

Construction Cost Estimate for Segment 15 of Illinois Route 43
(1991 Dollars)
Improvements Estimated Cost
Recommended
Roadwav $7,ISS,000
Intersection Improvement $1 ,200,000
Structure Modification so
Interchange Improvement $0
Transit Improvement $264,000
RiRhtofWav $4Sl,OOO
Total Estimated Cost for Recommended lmorovements $9.070.000
Short Term/Low-Cost
Roadway so
Intersection Improvement $0
Structure Modification $0
Interchange Improvement $0
Transit Improvement so
Ri2ht ofWay $0
Total Estimated Cost for Short Term/Low-Cost Improvements so
(Short Term/Low-Cost is also included in the Recommended Improvements Cost)
Ultimate (Post 2010) Improvements

Improvements, which are consistent with SRA policy, but are
considered best implemente~ beyond the 2010 horizon are
recommended for ultimate (post 2010) consideration. No
ultimate improvements are recommended in this segment.
Illinois Route 43 (c:SoYTl=
c.===========================================::::Jc=.J~---
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT ~ DEPA111'11ENT CJII 'llUINIIPOIITaTION 7
084
4.16 Segment 16: Walters Avenue to Lake-Cook Road
Location
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
lliinois Route 43 (Waukegan Road) Segment 16 extends from

Walters Avenue to Lake-Cook Road (See Figure 4.1.1 ). This
segment is approximately 2.0 miles in length and is located in
Northbrook and Deerfield.
Existing Facility Characteristics
The existing facility characteristics for Segment 16 of lliinois
Route 43 are shown on Exhibits ILL 43-23a through 24a.
Right-of-Way. The existing right-of-way in this segment varies
between 66 ft. and 100 ft. It widens out to greater than 1SO ft. at
the Interstate 94 interchange. ·
Roadway Characteristics. The pavement width in this segment
varies from 48 ft. to 66 ft. The pavement cross section includes
two through lanes in each direction with either no median or a
flush median that varies from 4 ft. to 18 ft. Curb and gutter is used
throughout the segment. Portions of the segment have sidewalk.
Widenings occur at Illinois Route 68 (Dundee Road) and Shermer
A venue for left turns.
Traffic Control/Intersection Details. There are six signalized

intersections in this segment:
Walters Avenue Interstate 94 (westbound ramp)
Shermer Avenue Chestnut Road
Illinois Route 68 (Dundee Road) Lake:-Cook Road
Throughout this segment IDinois Route 43 signal approach laneage

includes two through lanes in each direction with left tum lanes
provided. Between signals left turns are allowed at all cross street
and driveway locations. Three of the signalized intersections are
considered major: Shermer Avenue, Illinois Route 68 (Dundee
Road) and Lake-Cook Road. These are shown in Figure 4.16.2
Illinois Route 43
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT ~
=
(ccio"YD
c===============================:::=:====::;:====:Jc::::=...J~EX;..... 7
Dlil'AIOMINT Of' TIIAN-TATION
085
Figure 4.16.2: Existing Intenection Conf'aguration
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
A!~ All
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··~ :
Shenner Ave.
~ · · · · · ·~.; ~
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Structures. There is one structure along this segment.

Table 4.16.1: Existing Structure List
IDOT Facility Carried / Feature Crossed Width Length Horizontal Vertical

Structllre (feet) (feet) Clearance Clearance
Number (feet) (feet)
016-0305 ILL Route 43 (Waukegan Rd.)/ 72.0 302.0 N/A N/A
Interstate 94
Transit. The Metra Milwaukee District/North Line approaches the

corridor in this segment. Northbrook has a nearby station, located at
1340 Shermer Avenue. The Deerfield Station .is also nearby and
located at 860 Deerfield Road, which is two blocks west of Illinois
Route 43 and several miles north of Lake-Cook Road. Refer to Table
4. 16.2 for existing transit facilities and operations.
Illinois Route 43 ~ =
::=========================================c=.J~ ~-- ~
I
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT Dli".\ATMiNT OF TIIA-OIITATIDN
086
Table 4.16.2: Exlstlna Transit Facilities and Operations
Route Location Frequency Weekday Station Parking
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of Facility Boardings/
Ridership
Spaces %Use
Metra Rail Uncs and Nearest Station .
Milwaukee District/ 1340 Shermer Ave. Weekday: 22 IB, 26 OB 14S8 679 93.2
Nonh Linc Saturday: 9 IB, 9 OB
Nonbbrook Station Sunday: 7 IB, 7 OB
Milwaukee Dislrict/ 860 Deerfield Rd. Weekday: 24 IB, 26 OB 1669 768 89.2
Nonh Line Saturday: 9 IB, 9 OB
Deerfield Station Sundav: 7 IB, 7 OB
Pace Bus Routes
Pace 212 Along Waukegan Rd. Weekday: 20 NB, 18-20 SB 1049 N/A N/A
from Shermer Ave. Saturday: 11 NB, 10 SB
to Lake-Cook Rd. No Sunday or holiday service.
Pace 626 Crosses at Late- Weekday: 10 NB, 10 SB 450 N/A N/A
Cook Rd. No Saturday, Sunday or holiday
service.
Pace 471 From Deerbrook, Weekday: 5•28 NB, 5-27 SB 441 N/A N/A
along Waukegan Rd., Saturday: 1-13 NB, 1-13 SB
to areas north of No Sunday or holiday service.
Lake-Coot Road
Sources; Metta and Pace, "Future Agenda for Suburban Transponation" (April 1992). Pace,
"Ouartedy Route Review: January-March, 1992" (June 1992). Mctra and Pace, Individual
line/route timetables.
I(NB=nonhbound, SB=southbound, IB=inbound, OB=outbound)
Pace ridership is reported as average weekday ridership for 1992.
Existing Environmental Characteristics
The existing environmental characteristics for Segment 16 of

Illinois Route 43 are shown on Exhibits ILL 43-23a through 24a.
Streams/Wetlands/Floodplalns. Crestwood Park with an
identified wetland adjacent to the route is located southeast of
Illinois Route 68 (Dundee Road). Somme Woods Forest Preserve
with reported wetlands 1,000 ft. from the roadway is located on
both sides of Illinois Route 43 south of the Interstate 94
interchange.
Illinois Route 43
~
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7
087
Historical Significance. No sites of documented historical
significance are located along this segment. ·
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Hazardous Waste/LUST Sites. Two sites containing leaking

undergrowid storage tanks are reported along this segmen~ near
the Dundee Road and Shermer Avenue intersections.
• Illinois Bell Telephone, Waukegan Rd. & Shermer Ave.,
Northbrook
• Amoco Oil Co., Waukegan Rd. & Dundee Rd., Northbrook
Prime Farmland. No prime farmland exists along this segment.
Threatened and Endangered Species. Several threatened or
endangered species are known to exist west of the route within the
Somme Woods Forest Preserve.
Existing Land Use/Development Characteristics
Type and Intensity of Development. Land uses between Walters
Avenue and Shermer Avenue are primarily single-family
residential as shown on Exhibit Il.L 43-23a through 24a.
The SRA route passes through Somme Woods Forest Preserve
nonh ofIDinois Route 68 (Dundee Road) to Interstate 94 (l-94).
North of 1-94, on the east side of the SRA route, is Deerbrook Mall
Shopping Center. Brookside Plaz.a is on the southeast corner at
1-94 and residential land uses extend north to the Lake-Cook
County line on the eastern side oflllinois Route 43.
Development Access and Constraints. There are currently no
unusual land use constraints to development in this segme~t.
Future Development. No major development projects have been
identified by the local communities.
c'_1_u_n__o__i_s=R
=o=ut=-e___4=3==============:;=-======::;:;=::=:;:;===::1~fi... 1
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT - l)&l'jllllM&NT cw TM-OM-.TION
088
Recommended Improvements
Improvements. which are consistent with SRA policy, have been

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
developed by evaluating numerous factors including the year 2010

projected travel demand. the existing roadway characteristics. and
the character of development along the route. Recommended
improvements. for the 2010 timeftame. are shown on Exhibit ll.L
43-23b through 24b and summarized in Table 4.16.3.
Roadway. The recommended road configuration varies from

90 ft. to 100 ft. From Walters Avenue to illinois Route 68
(Dundee Road) the proposed 90 ft. to 100 ft. right-of-way consist
of two 12 ft. through lanes in both directions with an 18 ft. raised
median and parkways varying from 12 ft. to 17 ft. with curb and
gutter. From Illinois Route 68 (Dundee Road) to Lake-Cook Road
the proposed 100 ft. right-of-way consist of three 12 ft. through
lanes in both directions with an 18 ft. raised median and 5 ft.
parkways with curb and gutter.
90'-100' Pl'0POHd R.O.W.

• etMOO' Eldallng R.O.W
12·~1 7• 2-4' 18' :k'
• I I "I'
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Pro,ouct crou lectlon
•
100' ProJ)()ll84 R.O.W.
INl'-100' Emtlng R.O.W.
.
: 's· 1i git
·r
38'
·r ·r
38'
•
~ ·i-
I 1~ JI propoaect CroN ledlon

,~ i
I'
Illinois Route 43 0=::7DY-:fl=

c==========================================.::,c:=.)~~-
& UJ- 7
DPA"TINlfT 01' 'l'IUl. .l'Ol'Tl,1'10W
089
Table 4.16.3: Summary of Recommended Improvements
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Recommendations
1. Right-of-Way Width 90 ft.-100 t\. right-of-way from Walters Ave. to Illinois Route 68 (Dundee Rd.).
100 ft. rilZht-of-wav from Illinois Route 68 (Dwidee Rd.) to Lake Cook Rd.
2. Level of Service LOS CtoF
3. Number and Width of Two 12 ft. lanes in each direction within the 90 ft.-100 ft. right-of-way.
ThrouRh Lanes Three 12 ft. lanes in each direction within the 100 ft. riaht-of-way.
4. Median Width and Type 18 ft. raised median.
5. Parkways/Sidewalks/ 12 ft.-17 ft. parkways within the 90 ft.-100 ft. right-of-way.
Dra.inaee Ditch S ft. parkwavs within the 100 ft. ri2ht-of-wav.
6. SignaJimt Intersections There arc three major signalimf intcrscctions: Sbcnncr Ave., Illinois Route 68
-Major (Dundee Rd.). and Lake Cook Rd.
-Other Provide sitmal at 1-94 eastbound offramp.
7. Parking N/A
8. Curb Cut Access Provide median breaks at Woodhill Dr. and Thomwood Lane.
Riszht in/ruz:ht out elsewhere. Consolidate access.
9. Transit Provide signal preemption for buses. Provide directional signs to
nearby transit stations.
I 0. Pedestrian/Bicycle Provide pedestrian access to Forest Preserve, Crestwood School,
Facility Cmtwood Senior Housina. Decrbrook Shopping.
11. Loadina Off street only.
12. Miscellaneous Realign 1-94 eastbound off-ramp to permit access north.
Traffic Control/Intersection Configuration. PJI signalized

intersections in this segment should be interconnected with
actuated left tum phases. Dual left tum lanes and single right tum
lanes are recommended at all major intersections in this segment.
A signal is recommended at the Interstate 94 eastbound off-ramp
which would allow access northbound on illinois Route 43. The
expected level of service ranges from "C" to "F."
Parking & Access. No on-street parking is recommended for this
segment. Two additional left tum accesses using median breaks
will be provided in the Northbrook residential area at Woodhill
Drive and Thomwood Lane. Left tum access is provided only at
existing and proposed signal locations. Remaining access
locations are limited to a right in/right out configuration.
Structures. One structure will require modification to
accommodate the recommended roadway section as shown in
table 4.16.4.
c1_11i=
n_o-_i_s=R
=o=u=t_e___4=
3==============================:,JBtm];£+- 7
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT tWWC• DIPNmlliNT °' TMNll'otlTATtOH
090
Table 4.16.4: Structure Modification
IDOT Facility Carried I Feature Crossed Existing Proposed
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Structure Width Recommendation

Number (Feet)
016-0305 Illinois Route 43 (Waukegan Road)/ 72.0 Wideatoaa::ommodatc
Interstate 94 recommended section.
Transit Facilities. Between Shermer Avenue and IDinois Route

68 (Dundee Road), and again between I-94 and Lake-Cook Road,
bus stops should be located on-street at every block. but not closer
than 660 ft. All stops should be sheltered with sidewalk access;
except at the Lake-Cook Road intersection, they should be
generally located at the far sides of the intersections to
accommodate signal pre-emption and to facilitate transfers with
east-west routes.
All signals on Illinois Route 43 should be equipped for bus pre-
emption; all buses traveling on Illinois Route 43 should also be
equipped for signal pre-emption.
Directional signs to Metra's Milwaukee District/North Line station
at Northbrook should be installed at Shermer Road. Signs to the
Deerfield Station,just north of the terminus of the SRA. should be
installed at the Lake-Cook Road intersection. In anticipation of the
new Metra station at Lake-Cook Road, access from Illinois Route
43 should be planned.
Pedestrian/Bicycle Facilities. Pedestrian crosswalks should be
provided across Illinois Route 43 at several locations along this
segment. These locations include: Somme Woods Forest Preserve,
Meadow Brook School, Crestwood Senior Housing, Crestwood
School, and Deerbrook Mall.
Short Term/Low-C~st Improvements
Improvements, which are consistent with SRA policy, and are
short term (and or low-cost) are recommended for short term
( 1-5 years) implementation. There are no short term
improvements recommended in this segment.
Right-of-Way
The recommended right-of-way in this segment varies from 90 ft.
to I 00 ft. The takes vary from 24 ft. to 34 ft. throughout. The
right-of-way takes will be centered in the corridor.
Illinois Route 43
CHAPTER 4: CORRIDOR ANALYSIS BY SEGMENT -
~ =
c::::::=::::::::::::=======================::::::::::::::::::=::::::=:::::::::Jc=..}~U &i
DIPAlfflH"' DJ TIIAN-TATION
I
091
Potential Environmental Concerns
Toe recommended right-of-way expansion may require purchase
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
of multiple homes and land from the borders of Cook County

Forest Preserve holdings. Several plants on the Threatened and
Endangered Species List and identified wetlands within the forest
preserve and Crestwood Park need to be further studied.
Cost Estimate
The cost estimate shown in Table 4. 16.S for Segment 16 is

Sl2,.126.400.
Table 4.16.5: Cost Estimate

Construction Cost Estimate for Segment 16 of Illinois Route 43
(l 991 Dollars)
1mprovements Estimated Cost
Recommended
Roadway $8.105.000
Intersection lmprovement $1,100,000
Structure Modification $1,721.400
lnterchanae Improvement so
Transit Improvement $800,000
RiWltofWay $400,000
Total Estimated Cost for Recommended Improvements $12,116,400
Short Term/Low-Cost
Roadway $0
Intersection Improvement $0
Structure Modification $0
Interchange lmprovement $0
Transit Improvement so
Right of Way $0
Total Estimated Cost for Short Term/Low-Cost Improvements so
(Short Term/Low-Cost is also included in the Recommended Improvements Cost)
Ultimate (Post 2010) Improvements

hnprovements, which are consistent with SRA policy, but are
considered best implemented beyond the 20 IO horizon are
recommended for ultimate (post 2010) consideration. No
ultimate improvements are recommended in this segment.
Illinois Route 43
c========================================.:::.:::::7c::!JLJ'
CHAPTER 4: CORRIDOR ANALYSJS BY SEGMENT
-..~-~-u=-
°'
~-=
&
IW..,. Oll'AA'IIIIIIJT TMNal'OIITATIOOI
7
092
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

GROUP EXHIBIT 4
NORTHBROOK SPOT SPEED STUDIES

AND SPEEDING TICKETS
093
STATE OF ILLINOIS
DEPARTMENT OF TRANSPORTATION
DMStON OF HIGHWAYS' I BUREAU OF "FRAFFIC
SPEED ZONE STUDY (2000)
ROUTE: ILLINOIS 68 (DUNDEE ROAD) ZONE: 1 LENGTH: 0.85

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FROM: I - 94 (EDENS EXPWAY (East Ramps)J TO: West of BALLANTRAE DRIVE

M.S.# 0.16 M.S.# 24.98
CITY: NORTHBROOK T'MIISHIP: NORTHFIELD COUNTY: COOK
........................................................................................................................................................................................
PARTI SPOT SPEED STUDIES (ATTACHED) TOTAL CHECKPOINTS 4
10 MPH VIOLATION 10 MPH VIOLATION

CHECKPOINT 85th % PACE RATE CHECKPOINT 85th % PACE RATE
•tt••· ................ • • .,._..... ****...••· .........*.**""** • ..-• • • • ,, .. ,.. . . . ..,..,. • .--fr
.............._ .......,..-:Ci*• ......... *1'11:*1'-***•
1 CP# 1A (EB) 46.0 45.0 53.6 1~ .-1
6 0.0 0.0 o~o
2 CP# 18 (WB) 43.0 43.0 32.5 1 0.0 0.0 0.0
3 CP# 2A (EB) 48.0 46.0 55.4 8 0.0 0.0
4 CP # 2B (WB) 45.0 43.0 42.3
.., :i
C
9 0.0
0.0 0.0
0.0
5 0.0 0.0 0.0 10 0.0

0.0 0.0
***•••• .. ••..........'A'H*******•*****••..• ..••ttiA•*•....••-.-.•••••••••••..•..••••.... •••••• .. •••••••,..•.-.•• .. •• .. •1r• .. •••....•"1fr•••••••••••••••••••••****••
PART II PREVAILING SPEED PART Ill EXISTING SPEED LIMITS
85th % AVG.: 45.5 ZONE STUDIED: 40 MPH

UPPER LIMIT: 44.3 VIOLATION RATE: 46.0 %
NO. OF CARS IN Vl0LAT10N: 92
DIRECTION: WEST 45 MPH LGTH: 1.10
PREVAILING SPEED: 44.9 DIRECTION: EAST 30 LGTH: 0.30 MPH
..............................................................................._...........**•*tt•••H••••••••••....•••.. tt..........................,. ••• *•••****H••••
PART IV ACCESS CONFLICTS PARTY REDUCTION FACTORS
MAJOR STREETS(10x) 2 = 20 PEDESTRIAN VOLUME 10+/HR: 0

MINOR STREETS(5x) 3· = 15 PARKING PERMITTED: 0 > Y:: 1
LG BUS DRIVES(10x) 0 = 0 TOTAL NO. OF ACCOENTS: 102 N::O
SM BUS DRIVES(Sx) 7 35 NO. OF INJURY ACCIDENTS: 18
RES DRIVES(1x) 8 = 8 NO. OF FATAL ACCIDENTS: 0
ACCESS CONFLICT NUMBER TOTAL= 78 NO. OF HI ACC SEGMENTS: 1
ACCESS CONFLICT NUMBER/ MILE= 91.8 SEVERITY RATE: 0.18 ,J• •
A.D.T.: 37800
STUDY AREA RATE: 869.8
STATE AVERAGE RATE: 378
ACC FACTOR 870 I 378 : 2.30
PART VI SPEED ADJUSTMENTS PART VII REVISED SPEED LIMIT
ACC. CONFLICT ADJ. RECOMMENDED SPEED LIMIT: 40 MPH

PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATION RATE: 46.0 %
ACCIDENT ADJUST 0%
PARKING ADJUST 0% RECOMMENDED BY: MICHAEL STRAUSS-HODER
HI ACC LOC ADJ. 0% ORGANlZATION: BUREAU OF TRAFFIC
(max.10%) DATE: NOVEMBER 17 , 2000
*IF ACC ADJ + HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %* **Do You Wish To Apply Access Conflict Adjustment? 1 y =1
TOT. ADJ(max. 20%) 10 % N =0
44.9 X 10 % = 4.5 M.P.H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY:._ _ _ _ _ _ _ _ __
ADJUSTED f>REVAJUNG SPEED: 40.4 M:P.H.
DATE:._ _ _ _ _ _ _ _ _ _ _ __
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
094
STATE OF ILLINOLS
Ofl/lSK)N OF HtGHNAYS J 81.mEAU OF TRAFFIC
ROUTE: ILLINOIS 68 (DUNDEE ROAD) ZONE: 1 LENGTH: 0.85

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FROM: 1- 94 [EDENS EXPWAY (East Ramps)] TO: West of BALLANTRAE DRIVE

M,S. # 0.16 M.S # 24 .98
..................................................................................................................... .................................,.."'"'"••····- ·----

CtTY: NORTHBROOK TWNSHIP: NORTHFtELD COUNTY.
~
COOK
PART! SPOT SPEED STUDIES (ATTACHED) TOTAL CHECKPOINTS 4 .

...................
CHECKPOINT
......... ········· ..................... ....................
85th% PACE RATE CHECKPOINT 85th % PACE RATE
••·~*"'-**• .......... •..., .............
1 CP # 1A (EB} 46.0 45.0 53.6 6 0.0 0.0 0.0
2 CP # 1B (VVB) 43.0 43.0 32.5 7 0.0 0.0 0 .0
3 CP# 2A {EB) 48:0 46.0 55.4 8 o.a 0 .0 0.0
4 CP # 28 ('M3) 45.0 43.0 42.3 9 0.0 0.0 0.0
5 0.0 0.0 0.0 10 0.0 0.0 0.0
•--• • * •--•• • 11-•t•-,••• ................... ...,. .. *•...._ .................................... ,. •••• ,. .. •••• ••••• ••·••• ••••• •••• •••• .......... •••"'"*••••••-- ••-••• .. •1' •• • •11 .,,_ •
PARTII PREVAILING SPEED PART Ill EXISTING SPEED LIMITS
85th%AVG. : 45.5 ZONE STUDIED: 40 MPH

UPPER LIMIT: 44.3 VIOLATION RATE 46.0%
NO. OF, CARS INVlOlATION: 92
DIRECTION: WEST 45 MPH lGTH: 1.10
............................................................................................................................................. .............................. ............. ........
PREVAILING SPEED: 44.9 DIRECTION: EAST
,.
30 MPH LGTH:
._
0.30
~
PART IV ACCESS CONFLICTS PARTV REDUCTION FACTORS

MINOR STREETS(5x} 3 = 15 PAR!<,ilNG .PERMflTED: 0 > Y::: 1
lG BUS ORIVES(10x) Q = 0 TOT Al NO. OF ACCIDENTS: 102 N "'0
SM BUS DRIVES(5x) 7 = 35 NO . OF INJURY ACCIDENTS: 18
ACCESS CONFLICT NUMBER/ MILE= 91.8 SEVERITY RA TE: 0.18
A.0.T.: 37800
ACC FAC"VOR 870 / 378 : 2.30
.............................................................. ......................... tt •• . ......... ....................................... ...... ........ . . ...,. ....... • -..~4,... .
PART VI SPEED ADJUSTMENTS PART VII REVISED SPEED LIMIT / , ,. .,, f._...
(' ·i.·>" ·. . '
ACC. CONFLICT ADJ. 10 % .. RECOMMENDED SPEED LIMIT: 35 MPH 1-'v ·"
PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATION RATE: 79.5 % ,. ,. L . "
ACCIDENT ADJUST
PARKING AOJUST
Ht ACC 'LOC AOJ.
10 %
·0 %
0%
RECOMMENOEO BY:
ORGANIZATION:
MICHAa STRAUSS-HODER
BUREAU OF TRAFFIC
t' ''1t,,
(max. 10%) DATE: NOVEMBER 17 . 2000
"IF ACC ADJ + HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %• ··oo You Wish To Apply Access Conflict Adjustment? y =1
TOT. AOJ(max. 20%) 20 % N=O
44.9 X 20 % = 9 .0 M.P.H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED B
ADJUSTED PREVA\ltNG ~PEEID: 35.9 M.?.H. 0AJE _ _ _~/+-<_....,~~~--------
095
SiATE OF :LUNOIS
DIVISION OF HIGHVVAYS / BUREAU OF TRAFFIC
SPEED ZONE STUDY 2002
ROUTE: IL.43 (WAUKEGAN RD}

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ZONE· 1 LENGTH 1.23
FROM: VOLTZ RO , TO: IL.68 (DUNDEE RD)

M.S. # 43.30 M.S . # 44 53
CITY NORTHBROOK TWNSHJP NORTHFIELD COUNTY : COOK
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,., . . . . . . . . . . . . . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . . . . . . . . . " . . . . . . . . . . ... it . . . . . ........ ..... " i •• ,t., ........ -t,.

CHECKPOINT
i•~·······~•1~•·· ...........
85th % PACE RATE
. . . . . . . . . .._. ...... . . . . . . . .. '411 • • • •
CHECKPOINT
········~········
85th% PACE RATE
•11•---- ........................... ... ._ ,
1 CP#1NB :>0.0 51.0 65.0 6 CP#6S8 480 49.0 80 5
2 CP#2S8 50.0 51 .0 91 0 7 CP#7NB 49.0 50.0 80 5
3 CP#3NB 46.0 47 0 69 .0 8 CP#8S8 50.0 52.0 91 .5
4 CP#4SB 48.0 47.0 77.5 9 0.0 0.0 0.0
5 CP#5NB 460 47 0 76 0 10 00 0.0 00
.......... ............................,.......................................... , ,_....................................... ,. .................................. ,. ...... . .......... * ,, .... ............. . ..... .
PARTII PREVAILING SPEED PARTIII EXISTING SPEED LIMITS
85th % AVG .. 48.4 ZONE STUDIED: 40 MPH

UPPER LIMIT; 49 .3 VIOLATION RATE 81 4 %
NO. OF CARS 1N VIOLATION: 163
DIRECTION NORTH 45 M?H LGTH· 0 75
PREVAILING SPEED: 48.8 DIRECTION : SOUTH 45 MPH LGTH; 1.50
. . . . . . . . . . , . . . . . ., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . . . . . . . . . . . . . . 1111' . . . . . _.... • • ,.. _ _ . . . . . . . . . . . . . ,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ · · · ~ - - - - · · .. ... . . . . . . • • 11•• • I t . . . . "' . . . . .. ......... • . . . . . . . . . ...
MAJOR STREETS1 10x} 3 = 30 PEDESTR IAN VOLUM E 10• /HR 0

MINOR STREETS!'5x) 11 = 55 PARKING PERMITTED u .> y:1
LG BUS DRIVES(10x) 0 = 0 TOT AL NO. OF" ACCIDENTS 72 N=O
SM BUS DR!VES(Sx) 16 = 80 NO OF INJURY ACCIDENTS . i1
RES DRIVES(1x) 28 = 28 NO . OF FATAL ACCIDENTS 0
ACCESS CONFLICT NUMBER/ MILE= 156.9 SEVERITY RATE : 0 15
.A..D.T.: 20650
STUDY AREA R;,TE ~'76 6
STATE AVERAGE RATE 403
ACC . CONFLICT ADJ 10 % .. RECOMMENDED SPEED LIMIT.

PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATlON RATE
ACClDENT ADJU ST 0 %
PARKING ADJUST 0% RECOMMENDED BY · DAVID SCHROEDER
HI ACC LOC ADJ 0% ORGANIZATION BURE,'\U OF TRAFFIC
(max. 10%) DATE: MAY 1. 2002
·fF ACC ADJ + HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %• "Do You Wish lo Apply Access Conflict Ad1llS}(Tl~~t? y =1
TOT ADJ(max 20%) 10 % ,/.-·
48 .8 X 10 °/u "' 4.9 M .P H
PREVAI U NG SPEED ADJUSTMENT (max . 9 mph) APPROVED BY ,-
ADJUSTED PREVAILING SPEED: 43 .9 M.P .H. ...+
DATE: ___...;:~:,::. -l ....2'"-"'><-o+l....o,_,.,2,,e.c:...._ _ __ __
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _1_ _7_ _ _ _ _ _ _ __
096
STATE OF ILLINOIS
DIVISION OF HIGHWAYS/ BUREAU OF TRAFFIC
ROUTE: ILUNOIS 43 (WAUKEGAN ROAD} ZONE:

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
LENGTH: 1.13
FROM: WALNUT ROAD TO:

South of CENTRAL AVENUE
M.S. # 45.21 M.S. # 46.34
CPrY: DEERREL'O 'fWNSHlP; Northfield & WOeerfield COUNTY: Cook & LAKE
. ..........................................................................................................................................................................................
PARTI SPOT SPEED STUDIES (ATTACHED} TOTAL CHECKPOINTS 4

CHECKPOINT 85th% PACE RATE CHECKPOINT 85th % PACE
..................,..*** RATE
111*1t""11t'llo-.r* *~**""••** ,nll'*it****\\--lt1"tc*.,,. llil**•**·***""** ..... • ... ~1r1t•• **"'***...... " ..................
1 CP# 1A (NB) 46.0 45.0 49.8 6 0.0 0.0 0.0
2 Cl='# 1B (SB) 46.0 46.0 50.5 7 0.0 0.0 0.0
3 CP# 2A (NB) 47.0 45.0 57.4 8 0.0 0.0 0.0
4 CP# 28 (SB) 45.0 44.0 47.8 9 0.0 0.0 0.0
5 0.0 0.0 0.0 10 0.0 0.0 0.0
.........................................................................................................................................................................
85th % AVG .: 46.0 ZONE STUDIED: 40 MPH

UPPERUMff: 45,0 VtOLATION RArE: 51.4 %
00. OF CARS ~'N VIOLATION: 103
DIRECTION: NORTH 30 MPH LGTH : 1.00
......................................................................................................................................................................
PREVAILING SPEED; 45.5 DIRECTION: SOUTH 45 MPH LGTH: 0.53
MAJOR STREETS(10x) 4 = 40 PEDESTRIAN VOLUME 1O+/HR: 0

MINOR STREETS(5x) 2 = 10 PARKING l?IERMtiTTED: 0 > Y= 1
LG 9US ORI.VES(10x) 1 = 10 TOTAL NO. OF ACCIDENTS: 70 N=O
SM BUS DRIVES(5x) 11 =, 55 NO. OF INJURY ACCIDENTS: 8
ACCESS CONFLICT NUMBER/ MILE= 101.8 SEVERITY RATE: 0.11
,>?- A.D.T .: 30350
'--. STUDY AREA RATE: 559.2
r. ' STATE AVERAGE RATE: 403
-+, J
559 I 403 : 1.39
...............................................................
PART VI SPEED ADJUSTME ~ , 1 REVISED SPEED LIMIT
T hvr.:;. J d
ACC. CONFLICT ADJ. 10 %·· r.cv,s IDED SPEED LIMIT: 40 MPH
PEDESTRIAN ADJUST 0% :D VIOLATION RATE: 51.4 %
t ) ,,_ "•"'
ACCIDENT ADJUST 0%
PARKING ADJUST 0% IDED BY: MICHAEL STRAUSS-HODER
HI ACC l.OC ADJ. 5% 'ION: BUREAU OF TRAFFIC
(max. 10%) DATE: SEPTEMBER 6 , 2002
ADJ EXCEEDS 10 % USE 10 %.. ••oo You Wish To Apply Access Conflict Adjustment? 1 Y =1
TOT. ADJ(max. 20%) 15 % N-=O
45.5 X 15 % = 6.8 M.P.H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY:. _ _ _ _ _ _ _ _ _ __
DATE:._ _ _ _ _ _ _ _ _ _ _ _ __
ADJUSTED PREVAtt..lNG SPEED: 38.7 M :P.H.
097
STATE OF ILLINOIS
DEPARTMENT OF lRANSPORTATION
DIVISION OF HIGHWAYS/ BUREAU Of TRAFFIC
SPEED ZONE S'fUOY (2007)
ZONE 2.. LENGTH 1.81

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ROUTE: IL.43
FROM: NIOF FOUNDERS OR TO JL.68

M.S. # 43.02 M.S. # 44.53
CHY NORTHBROOK TWNSHJP. NORTHfJELD COUNTY. COOK
. . . . . . . 1'11 . . . . . . . . . . . ,, 111••« ......... ,. ........... .-.~ ................. . ...................................................................... ·-· ............ " .......... " •••• ,, ....... .....41: ........... .
PARTI SPOT SPEEO STUDtt:S(Al'TACHEO) TOTAL CHECKPOINTS 6
................... "'..
CHECKPOINT
......... .......... ............ .... -....................
85th% PACE RATE
.,., ,.,
CHECKPOINT 85th% PACE RATE
••••••• ,. ····~···· ......._. **.........
1 #3N 49.0 49.0 92.0 7 0.0 0.0 0.0
2 #4S 500 48.0 82.0 8 0.0 0.0 00
3#5N 47.0 41.0 11.0 9- 0.0 0.0 0-.0
4 #6S 47.0 47.0 66 .5 10 0.0 0.0 0.0
5 #7N 46.0 460 54.0 11 0.0 0.0 0.0
6 #8S 46.0 46.0 61.0 12 0.0 0.0 0.0
.......................... . . ~ - · ........................................ _, .. ,. • .,. ... ,_ ..... «,.. ................,, •• ,. ...................... ~ •• 11:.,,, . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..
PART 11 PREVAILING SPEED PART Ill EXISTING SPEEQ LIMITS
85th % AVG · 47.5 ZONE STUDIED 40 MPH

UPPER LIMIT. 47 .2 VIOLATION RATE 71 .1 %
DIRECTION · NORTH 45 MPH LGTH· 1.00

PREVAILING SPEED: 47.3 DIRECTION: SOUTH 45 MPH LGTH: 1.0+
PART IV ACCESS CONFLICTS PART V REDUCTION FACTORS
MAJOR STREETS(10x) 3 = ~w PEDESTRIAN VOLUME 10+/HR· 0

MINOR STREETS(5x) 11 :; 55 PARKING PERMITTED 0 > Y =1
LG BUS DRIVES(10¥} 0 : 0 TOTAL NO. OF ACCIDENTS· S1 N=O
SM BUS DRIVES(5x) 19 = 95 NO. Of INJURY ACCIDENTS: 17
RES DRIVES(1x) 28 = 28 NO. OF FATAt ACCtOENTS: 0
ACCESS CONFLICT NUMBER/ MILE= 114.9 SEVERITY RATE: 0.187
A.D T,: 24200
STUDY AREA RAlE: 5.692
ACC FACTOR 5 .692 / 3.878 : 1.468
................................... . ...,.......................................~...... _~···..·••M ................................. _ ..................................................... Jl, l
PART VI SPEED ADJUSTMENTS PART VII REVISED SPEED LIMIT , t.' ~O ~,J .)
4- c. le.~J• pi .,,,
ACC. CONFLICT ADJ. 10 % RECOMMENDED SPEED LIMIT: ~MPH A.. J.._ }_t1
0
,_,,
PEDESTRIAN ADJUST O% ANTICIPATED VIOLATION nATE 11 , 1 U:-6' % ~--1 'I• f 1'
ACCIDENT ADJUST O%
PARKING ADJUST O% RECOMMENDED BY. DAVID A SCHROEDER
HI ACC LOC ADJ O% ORGAN.IZf\TIQN'. BUREAU OF TRAFFIC
(max. 10%) DATE: MARCH 20 .2007
•tF ACC ADJ -t HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %• Y=1
TOT. ADJ(max 20%) 10 % N =0
47 3 X 10 % - 4 7 M.P H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph)
ADJUSTED PREVAILING SPEED·
PERTINENT COMMENTS.
42.6 M.P.H .
________________ _____________ ..,__
098
STAl E OF ILLINOIS
OOISION OF HIGHWAYS I BUREAU OF TRAFftC
SPEED ZONE STUOY (2007)
ZONE: LENGTH 1.81

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ROUTE: IL.43
FROM: WILLOW RO . TO: N/OF FOUNDERS DR

M.S. # 41 8-4 M.S.# 43.02
CITY: NORTHBROOK riNNSHlP: NORTI-TFJELO COUNTY: COOK
. . . . . . . . .,. . . . . . . . . . . . . . ,I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . ,.. . . . . . .,... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~. . . . . . . . . . . . . . . ~ . . . . . .
...................
CHECKPOINT
.,.. ......... ..........................
85tll% PACE RATE
...... .....
CHECKPOINT
, .,. "' ,,, .. .... 85th % PACE RATE
. . . . . . . , . . . . . . . . . . . . . . . . . . , . . • • ~ . . . . . . . JI,
0.0 0.0 0.0

1 #1N 520 52.0 64.0 7
2 #2S 51 0 51 .0 51:i.O 8 0.0 0.0 0.0
3 0.0 0.0 0.0 9 0..0. 0.0 0.0
4 0.0 0.0 0.0 10 0.0 0.0 0.0
5 00 0.0 0.0 1-1 0.0 0.0 0.0
6 0.0 0.0 0.0 12 0.0 0.0 0.0
85th % AVG.: 51 5 ZONE STUDIED: 45 MPH

UPPER UMlT: 51 .5 VIOLATIONRATE: 60.0 %
DIRECT:ON . NORTH 40 MPH LGTH: 1.0+

PREVAILING SPEED: 51 .5 DIRECTION . SOUTH 40 MPH LGTH: 0.70
...... .,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . flt . . . . . . . . . . . _ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . .. . . . . . . . . . . . . . . . . . . . ..
PART IV ACCESS CONFLICTS PARrV REDUCTION FACTORS
MAJOR STREETS(10x) 3 : 30 PEDESTRIAN VOLUME 10+/HR: 0

MINOR STREETS(Sx) 1 = 5 PARKING PERMITTED: 0 > Y =1
LG SUS DRIVES(10x} 2 "'° 20 TOTAL NO. OF ACCIDENTS; 80 N=-0
SM BUS ORIVES(5ic) 2 = to NO . OF iN.JURY ACCIDENTS . 20
ACCESS CONFLICT NUMBER TOTAL= 65 NO OF Hf ACC SEGMENTS. 2
ACCESS CONFLICT NUMBER / MILE= 35.9 SEVERITY RATE: 0.263
A.D .T : 24500
STUDY AREA RATE. 4.943
STATE AVERAGE RATE: 3.878
ACC FACTOR 4 .943 I 3 878 : 1.275
SPEED AOJUSTMENTS PARfWl R~SEO SPEED UMIT
ACC. CONFLICT ADJ. 0 %·· RECOMMENDED SPEED LIMIT: 45 MPH

~/c,I .t,_.-<
1,/ .J)
... ,
PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATION RATE: 60.0 % (:.-Y- f
ACCIDENT ADJUST 0% /1---
PARKING ADJUST 0% RECOMMENDED BY: DAVID A. SCHROEDER , , f.
HI ACC LOC AD.J. 10 % ORGANIZATION: BUREAU OF TRAFFIC 1,-;" V
(max. 10%) DATE: MARCH 20 .2007

•tF ACC AOJ + IH.f ACC lOC
ADJ EXCEEDS 10 % USE 10 %• .. Qo You Wish To Apply Access Confhct A~i[_nent? 0
TOT. AOJ(max. 20%) 10 %
51.5 X 10%= 5.2MPH
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY: '
ADJUSTED PREVAILING SPEED: 46 4 M.P.H. DATE :_ _ _...,..,..,.,.,,_ _ _ _ _ _ _ __
PERTINENT COMMENTS:-- - --- - - - - - - - - - - - - - - - - - - - - - - -
099
STATE OF ILLINOIS
. _Tbc·~ DEPARTMENT OF TRANSPORTATION
DIVIS/ON OF HIGHWAYS I BUREAU OF TRAFFIC
; f~ftclh --\-----1-. SPEED ZONE STUDY (2013)
~ O U T S = ILUNOIS 43 (WAUKEGAN ROAD) . · ji/ ZONE; 1
r<(
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
i-AvM: SOlrln of VOLTZ ROAD j, }J, }(; TO: North of ILUNO!S 68 {Otmdee f?~adl
M.S. II- -43.05 ( ,,, or M.S. # <M.73 \>
...........................................................................
CITY: NORTHBROOK ~~ J TWNSHIP: NORTHFIELD
t ll
COUNTY: COOK \i
ltaU:lt 1 .t•:t&•at11o•••••••••••••••••··...."
.FY""""""~ AOJUSTMB'JTS REVISED SPE.EO LIMIT

;e.
;_ / /
ACC.CONAJCT AOJ.
PEDESTRIAN ADJUST
10 %-
0%
~=-:-:::::==~___.:..~..:.-----~--- '"'-'\/t
R~OMJ,iet-.OED SPEEC .l.,iMl.,..:
ANTlClPATEO'v10lATIONRATE:
4,·
48.8
~1/r:t (3 \
ACCIDENT ADJUST 0% - - - - - - - --~·_.,, ti. '11
PARKING ADJUST O% RECOMMENDED BY:
HI ACC LOC ADJ. 0% ORGANIZATION:
(max.10%)
*IF ACC ADJ+ HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %~
TOT. ADJ(max. 20%) 10 o/o
-, 45.3 X 10 % = 4.5 M.P.H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY:
• ADJUSTED PREVAILING SPEED: 40.8 M.P.H. DATE:_ _ _ ..,_.,___ ____,:-c+~~""'--
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ . ~-- -..,..,~-.,,...
. ..,..,_ _ _ _ _ __ _ __
REQUESTED DAT.E '.;UMP'..ETEO DATA
,. A, , J')::/' ,._--;/.._, • _' r f
• ; ~ ' ._ I j .t, l l. ..•., f,t:':, ;
''I . - ·, .r-: _. ' :.,,· •· ,·, .: ,.y • I
::n. r
...
" }f..! I< C / , . :-· di.{· •<' ~ .-/ ..y.-i:.

'-..... ,,..,..,, . . .,
l'ISll#EEOFl~S 1 W411Xftllttllt
.....·-----~-
100
ST.ATE OF IUJNOtS
ONISION OF HIGHWAYS/ BUREAU OF TRAFflC
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ROUTE: SHERMEH ROAD ZONE: LENGTrl: 0.83
FROM: ILL 43 Road) 11/•✓aukegan TO: ILL 43 (Dundee Road)

M.SC #
2.75 MS.# 3.58
CllY: NORTHBROOK TWNSHIP: NORTHF!ELD COUNTY; COOK
.......................t••·· .............................................,,.......................................................................................
10 MPH VlOlATION 10 MPH VtOt.ATION
---
CHECKPOINT
1 CP# 1
85th % PACE .
........
380
..........
37.0
RA TE
..................
665
CHECKPOINT
aa&t•
7
I t aaa
85th % PACE
0.0
RATE
0.0 0.0
2 CP# 2 38.0 38.0 77.5 8 0 .0 0.0 0.0
3 0.0 0.0 -0.0 9 0.0 0.0 0.0
4 00 00 00 10 0 .0 00 0.0
5 ""·"'
" u.o 00 11 0.0 DO 0.0
6 0.0 0.0 0 ..0 l2 0 .0 0.0 0.0
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ._ . . , . . . . . . . . . . . . . . . . . . . . . . • $A$Mt.a•« .,.,.a,................. ,. ......_................. ........ MA ea• • ............
PART II PREVAILING SPEED PART Hf EXISTING SPEED LIMITS

UPPER I IM!T· 37 5 VlOLATfON RATE 720 %
DIRECTION: 0MPH lGTH: 0.00

PREVAILING SPEED: 37.8 OlRECTION: 0MPH LGTH: 0.00
~ ..... 1'1'..••w•••.....,•• ......... .,..~ .. •c.•••••• •...., .. .,.._.,. ...,.,.. .................... a •• •• ••• ................,. .,...__._..., .....,.. .... .,.._........ ,. ••• •• ••••••••••
MAJOR 9TREETS(10.-:) 2 = 20 PED€STRfAN VOUJME 11'.l+IHR: 0

MINOR STREETSt5x) 13 = 40 PARKING ?ERt,,UnED: 0 > Y =1
LG BUS ORIVES(10x) 0 = 0 HIGH CRASH LOCATION 0 > N=O
SM BUS ORIVES(5x) .2 = 10 A.O.T.: 12400
RES DRfVES(lX) 50 :: 50
ACCESS CONFLICT NUMBER TOTAL= 120
ACCESS CONFLICT NUMBER / MILE= 144.6
· · • ~·••
PART VI.
.....................................................................................................................,................................................,........
SPEED ADJUSTMENTS PART V J
-
ACC. CONFLICT ADJ. 10 %- RECOMMENDED SPEED LIMIT:
PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATION ~ATE:
ACCIDf:N~ ADJUST 0 "le
PARKING ADJUST 0% RECOMMENDED SY: MlCI tACL 3TRAUSS-HODER
HI ACC LOC AOJ. 0% ORGANIZATION: BUREAU OF TRAFFIC
(max. 108/o) DATE: JUNE 12 . 2014
"ff ACC AO.S + 4il ACC .11..0C
ADJ EXCEEDS tO % USE 1-0 %* :00 You Wish To APPlY Accm Conflict Mi5'rotQI? 1 Y• 1
TOT. ADJ(mu. 20%) 10 %
~HS X n PH
PREVAILING SPEED ADJUSTMENT (max 9 mph) APPROVED BY:
ADJUSTED PREVAILING SPEED: 34.0 M.P.H.
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
DATE: / 1( I t.{
_ _ __ _
'f/r.iJtf
REQUESTED DATE COMPLETED DATE
101
STATE OF tlUNOIS
DEPARTMEl.\(J; OF TRANSPORtAl\ON:
OMSION OF HtGHWA¥S I et>Rf:AU OF l'RAFFIC
SPEED ZONE STUDY (201'5)
ROUTE: ILl.lNOIS 43 (WAUKEGAN ROAD) ZONE; 1 LENGTH: 1.10

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FROM: 0.1 mile North of WILLOW ROAD TO: 0.25 mile South of VOLTZ ROAD
M.S. # 41.94 M.S. # 43.05
...................................................... ,..................................................................................................
ClTY: .NORTHBROOK TWNSHJP: NORlliFIELO COUNTY: COOK
10MPH VIOLATION
---
10 MPH VIOLATJON
CHECKPOINT
....................,....
1 CP# 1A (NB)
85th% PACE
50.0 49.0
...............
RATE
43.2
CHECKPOINT
..........•••• ,.A.aM
1
85!h% PACE RATE
........... ~ .. .........
._
0.0 0.0 0.0
2 CP # 1B (SB) 51.0 51.0 52.2 8
g
0.0 0.0 o.o
3 0.0 0.0 0.0 0.0 0.0 0.0
4 0.0 o.o: O'.O 10 O;O u.o 0.0
5 0.0 0.0 0.0 11 0.0 0.0 0.0
6 0.0 0.0 0.0 12 0.0 0.0 0.0
85th % AVG.; 50.5 ZONE STUDIED: 45 MPH

UPPER LIMIT: 50.0 VIOLATION RATE: 47.7 %
flJRECTION: NOR11H 40-MPH LGJH: 1.80

.,.,,.,
50.3 OfN:CTION: sourli
...........................................................................................................................................................
40MPH LGTH: 0.60
PARTIV ACCESS CONFLICTS PARTV REDUCTION FACTORS
MAJOR STREETS{10x) 1 QI 10 PEDESTRIAN VOLUME 10+/HR: 0

MINOR STREETS(5x) 1 • 5 PARKING PERMITTED: 0 > Y= 1
LG BUS ORIVES(10x) 1 "' 10 HIGH CRASH LOCATION: 0 > N=O
SM BUS ORIVES{5x) 4 = 20 A.O.T.: 21300
RES ORlVES{1x) 0 = 0
ACCESS CONFLICT NUMBER TOTAL,,. ~
ACCESS CONFLICT NUMBER/ MILE= 40.9
PARTVl SPSED AOJUSNENTS PARTW REVISED SPEED UMff
ACC. CONFLICT AOJ. 5%- RECOMMENDED SPEED LIMIT: 45MPH

PEDESTRIAN ADJUST 0% ANTICIPATED VIOLATION RATE: 47.7%
ACCIDENT ADJUST 0%
HI ACC LOC ADJ. 0% ORGANIZATION: BUREAU OF TRAFFIC
(max. 10%) DATE: FEBRUARY 20 • 2015
"IF ACC AOJ + HJ ACC LOC
ADJ EXCEEDS 10 % USE 10 %• 1 Y=1
TOT. ADJ(max. 20%) 5% N=O
50.3 X 5 %= 2.5 M.P.H.
ADJUSTEO PREVAILING SPEED: 47."! M.P.H. DATE:p..:2-/.2!. _
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ -=---------------
102
STATE OF il:...t-.0 S
'JE?AR7.\EN7 OF TRA~?ORT.\-iOK
:)!VISION OF H!Gi-fWAYS / BUREAU OF TRAff;C
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ROUTE: l~INOIS 43 (WAUKEGAN ROAD) ZONE: 2 LENGW: 1.70
F~M: Scuth of V:il1Z ROA:> TO:

l'temoi ILI.INOIS 68 {Juniee Road;
M.S.# 43.GS M.S.# 44.73
CITY: 1'.0RTHaROOK T~J.NSHAP: NORTHflELD COOK
......."'......................... -.. ••za:.• •• k _ k ble:;a,1:J l • • ~ _ . . , . • • 114 . . . . . t ... , <wllia.ltwt:••• .................. ••·••• a • Q@ • A I# ...............
PAP.Tl SFOT SPEED Sn.JO:ES {ATTACHED) TOTAL CHE:KPO:NTS 5
10MPH VIOLATION 10 MPH ViQLATi ON
--
CHECKPOINT
1 CF#
2 CP -C
1A (NB)
18 (SS)
85:h % PACE
.............
46.0
47.C
_.......,....
47.0
RATE
_ . , . ••
61.5
iltl ....-.
CHECKPOINT
• 444
7
I 6 • ..._..._.
85th % PACE
0.0 0.0
RATE
0.0
47.0 59.6 B 0.0 0.0 0.0
3 CP# 2A \~) 45.0 Ao.0 47.5 9 o.c 0.0 0.0
4 CP# ZB rss) 46.0 46.0 55.4 to O.G 0.0 0.0
5 CP # 3A :NB) 44.0 45.0 42.5 11 O.C 0.0 0.0
6 CP# 38 (SB)
. . . . . . . . . J-Wlt444 4£.J,l4wPilt:&44 il
45.0
4
45.0 46.8
. . . . . . . . . . . . . . . . . . . . . . . . . lfA•*•laal.:..4
12
ta:l:w• k
o.c
.............................. , . . . . . . . •··•
0.0
• •a
0.0
.,, . . . . . . . . . . . . . .._ _ _.."'••-••. . . . . . . 1".... .........
PART II PREVAILING SPEED PART Ill u<lSTING SPED :..IM!TS

UPPER UMT: 45.8 VJOLA7CN RAft;; 52.3 %
D1RECTiON: NORTl-1 45M?H LG~: 0.53

Pf?EVAl:..!NG SPEED: 45,8 D!RECTION: SOUTH 45MPH LGTI-:: 1.15
?A.~TIV ACCESS CONFLICTS ?ARTV REOUCTION FACTORS
MAJOR ST~E!:TS(1 Ox) 4 = 40 PEDESTRIAN VOLUME 10+/HR; 11

MINOR STREETS(5x) 10 = 50 PARKJNG PERMITTE::>: O> Y.a1
LG BUS DRIVES('lOx) 0 :: 0 HIGH CRASH LOC.6-T10N: :) > N=0
SM BUS DRIVES(5x) 12 = 60 A..D.T.: 21400
RES 0Rl\lES(1x} 29 .,. 2S
ACCESS CONF:..;c- NUMBER TOTAL: t79
ACCESS CONFUCT NJMBER / MILE= 105.3
?ARTVl SPEED ADJUSTMENTS PARTVII R2"1SED SPEED LIMIT
ACC. CONFLICT ADJ. 10 %- RECOMMEt\DED SPE:D LIMIT: 4DMPH

PEDESTRIAN ADJUST 5% A'IITICIPATED VIOLATION RATE: 52 .3%
ACCIDENT ADJUST 0%
HI ACC LOC ADJ 0% ORGANIZATION: BUREAJ OF TRAFFIC
(max. 10%) DATE: OCTOBER 8 2015
•fF ACC ADJ + HI ACC LOC
ADJ EXCEEi)S 10 % USE 1!:t %• y .. 'f
TOT. AOJ(max. 20%) 15 o/o
45.6 X 15 ¼ =- 6.9 M.P.H.
PREVAILING SPEED A:>JUSTII.ENT (max.. 9 mph) APPROVED BY:
ADJUSTED PREVAILING SPEED: 39.0 M.PJi. DATE:......,....,........,......,...._,_-.....,_,..,.__.,.__ _ _ __
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ _ _ __
REQUESTED DATE COMPL:.7ED DAT=
103
STAl'E OF llt.lN'OfS
OEPAEUMl:Mt OF TRANSPORTATION
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ROUTE: ILLINOIS 43 (Waukegan Road) ZONE: 2 LENGTH: 1.50
FROM: 0.25 miles Soulh of VOLTZ ROAD TO: JlUNOIS 68 (Dundee Road)
M.S. # 43,05 M.S.# U.56
CITY: NORW.BROOK 1WNSHiP: NORTHFl8LD COUNTY: COOK
~,.,..........................,nntnw,•················.........'lil.llt............................. ....... •.............. aAkkAl4wtaHlt&••················ .•.. ,.
PAR.Tl SPOT SPEED STUDIES (ATTACHED) TOTAL CHECKPOINTS 6
10MPH VIOLATION 10 MPH VIOLATION

CHECKPOINT
u ........... u,u
1
2
CP #
CP #
1A (NS)
1& (SB}
--
85th% PACE
47 .0
47.0i
47 .0
Fo&.Q.
RATE
,,,.............hff...
55. i
55.7
............,........
CHECKPOINT
1
a
85th % PACE
...............
0.0
0.0
.........................,... ,_,
RATE
0.0
0.0.
0.0
0..0
3 CP # 2A (NB) 45.0 45.0 47 .0 9 0.0 0.0 0.0
4 CP# 2S (SB} 46.0 46.0 55.7 10 0.0 0-.0 0.0
5 CP # 3A (NB) 44.0 43.0 37.9 11 0.0 0.0 0.0
6 CP # 3B (SB} 44.0 44.0 38.4 12 0.0 0.0 0.0
... , .,.,.., .............. ,.I •••• ,, .......... ,u •• , •• ••••• .-. ....... ,, •••• **. *•• , • *****d A.......,..~ ••••• ,., ...... ,.,,.,.·~ •• aA.U.la*uu ............... J.,." AAUA• .........
PART It PREVAILING SPEED PART Ill EXISTING SPEED LIMITS
85th % AVG.: 45.S ZONE STUOiEO: 40 MPH

\JP?ER -UMIT: 45.2 VtOl.AT-JON ,RATE.: 48.3 "%
O!RECTION: NORW-I 40MPH LG1H: 1.90

PREVAILING SPEED: 45.3 DIRECTION: SOUTH 46 MPH LGTH: 1.15
............................................................. Ji .......... *' ••••• HI u ............. ii •••• ••a ii ••••••••• .., •••• , . . . . . . . . . HUJ•••u .. u .......u .....
MAJOR STREETS(1 Ox) 4 = 40 PEDESTRIAN VOLUME 10+/HR: 0

MINOR STREE.TS(5x} 10 a: 50 PARKING PERMITTED: 0 > Y= 1
LG BUS DRNES(10q O = 0 HIGH CRASH LOCATION: Cl:>N=O
SM BUS ORIVES{5X} 12 = 60 A.O.T..: 20100
RES DRWES{'fx) = 29 29
ACCESS CONFLICT NUMBER TOTAL= 179
-ACCESS CONFLICT NUMBER / MILE= 119.3
........,...... .......... ..........,, . . . . . . J:Aftl. l:l10J.t ,llltU ......... ,..tl.............................................~....,., ........ :u1:u1e1twtr1·... ··••*'•••11,. •• ,. ........ *Ut:,.
PAR'fW REVISB> SPEED UNIT
ACC. CONFLICT ADJ. 10 °Iott RECOMMENDED SPEED LIM4T: 40Mf'ti

ACCIDENT ADJUST 0%
(max.10¾} DATE: JULY 19 , 2017
*IF AC.C .ADJ + Hf ACC LOC
ADJ EXCEEDS· 10 % USE 10 %* 1 Y=t
TOT. ADJ(max. 20%.) 10-% N•O
45.3 X 10 % = 4.5 M.P.H. , / /IA.~/
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY: if• (ff•~
ADJUSTED PREVAILING SPEED: 40.8 M.P.H. DATE: '7- t u - ~ ~ -
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _
104
5 i5 20 25 30 35 40
r-- 20
,....-
z
s~ ~
g 21 .
22
I
'
~
Q~
> 23
24
"'0 !::
25
.26,.,., ·---
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Q
Qi
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·-c
i1~
0
n.
28
r1Q
"--
-... ~! . Ill> ...

30
31 ·---
/'·-....
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32
33
34
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0
36
37
38
39
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ft;
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.
--
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41
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45
l'6
,;.I·::1 . . . ....
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r;!_' :1, ~ &l t 46 :rz;
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w
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.60
61 ' i f I ---
62 I
63
64
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65
66 ----
67
68
69 l
70
7i I
--
72 I
73
74
75
76 -
n I
78
7g
80
~1 -
82
83
84
85 _... ..,_
ABOVE xS LIST INOIVIOUALLY:
105
5 10 15 20 25 30 35 40
2{; 1 I
21 r J
- I l
--
22
23
24
25
26
·----
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
27
28
29
30
31
--
32
33
34
35
J§
·-·---
,I
37
38
39
ii • "4 \~
40
Tr-- I
41
4
.. '
,. -.
;., ,
Ci\\.
l fil.-- 0~ .
43 I I 1%-
44 13
45 .Lt. qJ
2Z---
46
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48
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4
•Z-
j 5 3' 50 .,
I ""'
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-;;_:~-
> '.re~.,,),, 51
Q
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...:; 52 I I
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53
ti 54
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55
56
57
·---- ...
58
59 I I •
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C. 60 L I I
i_____
l
(/J 61 I
. 6362 I I I I
t
64 ..
65
66
·-----
67
68
-69 t 1
70
. 71
.I
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I I ! ! r 1.
---
72 I
73
74
76
76
-------
77
78
79 •
80
81
I
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01/13/17 Speeding WAUl(EGAN BD & SHAG SARI< LN. Northbrook, IL 60062

00./25/17 Speeding WAU 11'.EGAN IW. & JEFFERY lcN Northbrook, Ii. 60062'
£13/26/1-7 Speeding l'.400 WAUK!:GAN' RO Nol"thbrook, 11. 60062
04/D2/17 Speedmg 900 WAUlCEGAN RO Northbrook, tt: 60062
04/02/17 Speeding WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
05/23/17 Speeding MAPLE AVE & WAUKEGAN RD Northbrook, IL 60062
05/23/17 Speeding SHERMER RD & WAUKEGAN RD Northbrook, IL 60062
05/23/17 Speeding WAUKEGAN RD & SHERMER RD Northbrook, IL 60062
07/30/IJ.7 Speeding 26-34 over ~eed WAUKEGAN RD & SHERMER RD Northbrook, lL 60062
08/01/17 Speeding WAUKEGAN RO & VOl.TZ RD Northbrook, IL 60062
08/19/17 'Speeding WAU.KEGAN RD & ,Mf\PLE AVE Northbrook, 11 60062
09/29/17 Speeding WAUKEGAN RD & MAPLE AVE Northbrook, IL 60062
10/12/17 Speeding WAUKEGAN RD & CHAPEL CT Northbrook, IL 60062
10/18/17 Speeding 35+ over speed I WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
11/08/17 Speeding WAUKEGAN RD & WOODHILL DR Northbrook, IL 60062
11/20/17 Speeding 1000,WAUl<EGAN RD Nor,thibrook, I[ 60062
11/20/17 Speeding 1000 WAUKEGAN RD Northbrook, IL 60062
01/01/18 Speeding SHERM6R ROI.I WAUKEGAN RONO!!thbuook, IC. 6'>062
01/31/18 Speeding 35+ over speed WAUKEGAN RD & PORTSMOUTH CT Northbrook, IL 60062
05/U/18 Speeding WAUKEGAN RD & SHERiMER RO Nortnbrook, a 60062
06/06/18 Speeding WAUKEGAN RD & WALTERS AVE Northbrook, IL 60062
113
1/8/08 Speeding VOLTZ RD & WAUKEGAN RD Northbrook, lL 60062

FILED DATE: 5/6/2019 12:00 AM 2019CH05641

03/23/08 Speeding WA-UKfGAN RO & 01APEi. CT Northbrook, tl 60062
03/28/08 Speeding VOLTZ RD & WAUKEGAN RD Northbrook, IL 60062
03/31/08 Speeding WAUKEGAN RD & WALTERS AVE Northbrook, IL

04/16/08 Speeding WAUKEGAN & VOLTZ Northbrook, IL 60062
04/17/08 Speeding 1500 WAUKEGAN RD Northbrooi(, IL 60062


05/02/08 Speeding MAPLE AVE & WAUKEGAN RD Northbrook, Jl 60062
05/04/08 WAUKEGAN RD & VOLTZ RD Northbrook, IL 6006,2
Speeding
05/14/08 Speeding
1600 WAUKEGAN RD Northbrook, IL 60062
05/14/08 Speeding
09/02/08 Speeding
09/09/08 Speeding WAUKEGAN- RO & VOlTZ RD Northbrook, ll 60062
11/01/08 1000 WAUKEGAN RD Northbrook, lL 60062

Speeding
11/14/08 WAUKEGAN RD & MAPLE AVE Northbrook, IL 60062
Speeding
01/15/09 Speeding
01/15/09 Speeding
02/21/09 Speeding
1200 WAUKEGAN RD Northbrook, ll 60062

Speeding
Speeding
03/25/09 WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
Speeding
04/25/09 Speeding
1400 WAUKEGAN RD N.ortbbrook, lL 60062
05/0 9 /09 SPEEDING> 40 OVER POSTED WAUKEGAN RD & SHERMER RD Northbrook, IL 60062

Speeding
Speeding
08/24/09 Speeding
114
09/28/09 Speeding WAUKEGAN RD & SHERMER RD Northbrook., ll 60062

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
10/30f,09 Speeding 1400 WAUKEGAN RD Northbrook, 1l 60062
11/12/09 Speeding WAUi<EGAN RO & WAlTERS AVE Northbrook, IL
02/19/10 1000 WAUKEGAN RD Northbrook, IL 60062

Speeding
03/19/10 Speedi11g 1000 WAUKEGAN RD Northbrook, ll 60062
03/19/10 WAUKEGAN RD & WOODHlLL DR Northbrook, IL

Speeding
Speeding
Speeding
Speeding
06/17/10 Speeding
WAu-KEGAN, Rlil & VOLliZ RE> Northbrook., 1"1. 60062
06/24/10 1200 WAUKEGAN· RD N'ollthbrook, It 60062

Speeding
Speeding
Speeding
Speeding
07/21/10 900 WAUKEGAN RD Northbrook, lL 60062
Speeding
08/03/10 WAUKEGAN RO & WAUERS AVE Northbrook, IL
Speeding
Speeding
Speeding
08/21/10 WAUKEGAN RD & MAPLE AVE Northbrook, ll 60062
Speeding
10/30/10 WAUKEGAN RD & VOLTZ RD Northbrook, It 60062
Speeding
Speeding
Speeding
12/24/10 WAUKEGAN RD & JEFFREY LN Northbrook, IL 60062
Speeding
115
01/02/11 Speeding 1200 WAUKEGAN RD Northbrook., IL 60062
01/16/11 Speeding WAUKEGAN RD & CHAPEL CT Northbrook, IL 60062

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
03/29/11 Speeding 1000 WAUKfGAN RO Northbrook, tl 60062
06/26/11 Speeding 1100 WAUKEGAN RD Northbrook, rl 60062

Speeding
10/26/11 WAUKEGAN RD & SHAG BARK LN Northbrook, IL
Speeding
12/12/11 Speeding
WAUKEGAN. RD & SlnERMER RO Northbrook, lilL 60062
01/01/12 1200 WAUKEGAN RD Northbrook, !l 60062

Speeding
Speeding
01/22/12 WAUKEGAN RD & SHERMER RD Northbrook, IL 60062
Speeding
Speeding
02/05/12 1200 WAUKEGAN RO ,Northbroo4<, Ai. 60062
Speeding
02/25/12 WAUKEGAN RO & VOLTZ RD Northbrook, IL 60062
Speeding
Speeding
Speeding
04/01/12 1500 WAUKEGAN RD Northbrook, LL 60062
Speeding
Speeding
Speeding
Speeding
Speeding
116
03/17/13 Speeding WAUKEGAN RD & VOLTZ RD Northbrook, lL 60062

FILED DATE: 5/6/2019 12:00 AM 2019CH05641

Speeding
05/24/13 WAUKEGAN RD & CHAPEL CT Northbrook, IL 60062
Speeding
05/28/B Speeding 1500 WAUKEGAN ,Ri[) Northbrook, ~,L 60062
08/23/13 Speeding WAUKEGAN RO & CHAPEL CT Northbrook, JL 60062

SpeediOB
01/17/14 Speeding 1400 WAUKEGAN RD N'orthbrook, It 60062
03/15/14 Speeding 1400 WAUKEGAN RD Northbrook, rt 60062

Speeding
05/09/14 WAUKEGAN RD & WALTERS AVE Northbrook, IL

Speeding
Speeding
Speeding
07/22/14 WAUKEGAN, Q'D & VOi.1Z RO N,orthbrook, kl 60062
Speeding
07/23/14 WAUKEGAN RD & VOLTZ RD North.brook, Jl 60062
Speeding
Speeding
Speeding
Speeding
09/23/14 WAUKEGAN RO & VOLTZ RD Northbrook, Ii 60062
Speeding
09/27 /l 4 SPEEDING > 40 OVER POSTED WAUKEGAN RO & MAPLE AVE Northbrook, IL 60062
11/08/14 WAUKEGAN RD & JEFFREY LN Northbrook, IL 60062

Speeding
Speeding
11/09/14 WAUKEGAN RD & VOLTZ RD Northbrook, ll 60062
Speeding
Speeding
Speeding
12/19/14 VOLTZ RD & WAUKEGAN RD Northbrook, IL 60062
Speeding
Speeding
117
02/17/15 Speeding 1300 WAUKEGAN RO N.orthbrook, ll 60062
03/07/15 Speeding VOLTZ RD & WAUKEGAN RD Northbrook, IL 60062

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
03/24/15 WAUKEGAN RD & LINDEN RD Northbrook, IL 60062

Speeding
03/28/15 Speeding 1400 WAU~GAN .00 tiorttwbrodk, ll. 60062
Speeding
04/06/15 Speeding WALTERS AVE & WAUKEGAN RD Northbrook, IL
04/06/15 Speeding WALTERS AVE & WAUKEGAN RD Northbrook, IL
04/15/15 Speeding MAPLE AVE & WAUKEGAN RD Northbrook, IL 60062
04/16/15 Speeding WAlJl<fEGAN• llID & MA?ll.lt AV!t IW'Orthbrook, Ni. 60062
05/04/15 ~peedjng MAPLE AVE & WAUKEGAN RD Northbrook, Jl 60062
05/09/15 Speeding WAUKEGAN RD &VOLTZRD Northbrook, IL 60062

Speeding
Speeding
05/16/15 WAUKEGAN' RD & VOi,.liZ i'O Northbrook, Ldl. 60062
Speeding
Speeding
Speeding
06/04/15 WAUKEGAN RD & CHAPEL CT Northbrook, IL 60062
Speeding
Speeding
07/12/15 WAUKEGAN RO & MAPl.E AVE Northbrook, ll 60062
Speeding
Speeding
08/23/15 VOLTZ RD & WAUKEGAN RD Northbrook, IL 60062
Speeding
08/2 3/l5 SPEEDING> 40 OVER POSTED WAUKEGAN RD & WALTERS AVE Northbrook, IL
09/21/15 WAUKEGAN RD & VOLTZ RD Northbrook, lL 60062

Speeding
Speeding
Speeding
Speeding
Speeding
118
11/18/15 Speeding, WAUKEGAN RD & StiERMER RD Northbrook, IL 60062

Speeding
FILED DATE: 5/6/2019 12:00 AM 2019CH05641

Speeding
03/15/16
Speeding WAUKEGAN RD & VOJ..TZ RD -Northbrook, ll 60062
04/11/16
Speeding WAUKEGAN RO & WALTERS AVE Northbrook,

Speeding
05/10/16
Speeding SHERMER RD & WAUKEGAN RD Northbrook,
05/12/16
Speeding WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
05/19/16 Speeding WAUKEGAN RO & W~LLOW RD Northbrook,
06/23/16 Speeding WAUKEGAN RD & VOtT2 RD Northbrook, IL 60062

Speeding
09/13/16 Spee&ng SHERMER RD & WAUKEGAN RD Northbrook, IL 60062
10/07/!G SPEEDING > 40 OVER POSTED WAUKEGAN RD & MAPLE AVE Northbrook, IL 60062
10/18/16 Speeding
WAUKEGAN RD & SHERMER RD Northbrook, IL 60062

Speeding
01/13/17 Speeding WAUKEGAN RD & SHAG BARK LN
02/25/17 Speeding WAUKEGAN QI> & .liltlrlrERY L..N Northbrook,
03/26/17 Speeding 1400 W A UKEGAN RD Northbrook, IL
04/02/17 Speeding WAUKEGAN RD & VOLTZ RD Northbrook,
05/13/17 Speeding WAUKEGAN RD & VOLTZ RD Northbrook,
05/23/17 Speeding MAPLE AV1E & WAlJK EGAiN 'RO 'Northbrook,
05/23/17 Speeding SHERMER RD & WAUKEGAN RD
05/23/17 Speeding WAUKEGAN RD & SHERMER RD
07/30/17 speed WAUKEGAN RD & SHERMER RD
08/01/17 Speeding WAUKEGAN RD & VOLTZ RD N0rthbr0ok,
08/19/17 Speeding WAUKEGAN RO & MAPLE AVE Northbrook,
09/29/17 Speeding WAUKEGAN RD & MAPLE AVE Northbrook,
10/12/17 Speeding WAUKEGAN RD & CHAPEL CT Northbrook,
119
10/18/17 speed I WAUKEGAN RD & \I0L TZ RD Northbrook,
11/08/17 Speeding WAUKEGAN RD & WOODHILL DR
11/20/17 Speeding 1000 WAUKEGAN RD Northbrook, IL
FILED DATE: 5/6/2019 12:00 AM 2019CH05641

01/01/18 Speeding SHERMER RD & WAUKEGAN RD
01/19/18 Speeding WMJKEGAN RD & V0LifZ RD Northbrook,
01/31/18 speed WAUKEGAN RD & PORTSMOUTH CT
02/11/18 Speeding WAUKEGAN RD & MAPLE AVE Northbrook,
05/11/18 Speeding WAUl<EGAN RD & SHERMER RD
06/06/18 Speeding WAUKEGAN RD & WALTERS AVE
/ /08 Speeding 1600 WAUKEGAN RD Northbrook, IL 60062
/ /08 Speeding WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
I /OB Speedin.g WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
WAUKEGAN RO & VOLTZ RO Northbrook, ll 60062

/ /08 Speeding
WAUKEGAN RD & VOLTZ RD Northbrook, IL 60062
/ /08 Speeding
120
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

GROUP EXHIBIT 5
IDOT LETTERS TO NORTHBROOK

REGARDING SPEED LIMITS
121
Hlinois Department of Transpo
Division of Highways/District ,
201 West Center Court/Schaumburg, Illinois 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) IL 68 (Dundee Ave)
February 6. 2001
The Honorable Kathleen Parker

Illinois State Senator
Twenty-ninth Legislative District
191 Waukegan Road
Suite 204
· To:
Northfield. IL 60093 To:
• f ... laforJDation
Dear Senator Pmker: A=Action
This is a follow-up to our interim leUer of September 15.. 2000 regardin

on IL 68 (Dundee Ave.) west of the Edens Expressway. ~
A traffic and engineering speed study was recently conducted on IL 68 (Dundee Ave.)
from the 1-94 east ramp junction to west of the Northshore R. R. overpass in
Northbrook. The results indicate that the present 40 mph speed limit s~fd be 35 mph.
Signing revisions have been ordered, and wiU be done as soon as our wort schedule
will allow.
We have requested the Northbrook Police Department to increase their selective

enforcement in this new zone to ensure that the new limit is observed.
If you have any questions or need additional infonnation, please contact me or John
Schwarz, Traffic Programs Engineer. at (847) 705-4158.
Very truly yours,
John P. Kos, P .E.

District Engineer
bee: James C. Slifer

Matt Davidson
John P.K.os
Roy Fonda
John Schwarz
Lisa Heaven-Baum
Prepared By: Rodger Neubert, cxt.4472
S \Ocn\WP\.Stlldalp,010206.doc
122
IIDnois Department of Transpo$,ti9~
Division of Hfghwaya/Dlatrrct 1 i ll ·;, · : .. ··•·. 1•
201 West Center Court/Schaumburg. ffUnofs 60196-1096 f ~ -·~ _ c; ~ , ~ :. •
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
1---__ . . . _ .......
ST 3.l (q IL 43 (War.rkegan Raad)
May 21. 2002
Chief of Police
Northbrook Police DepartmaJt
140 l Landwehr Road
Nnrthbrook, IL 60062
Dear Chief of Police:

.----·--· ---, --· ---·
.
A traffic and engineering speed study was conducted on IL 43 (Waukegan
Road) between Voltz Road and IL 68 {Duadee R.oa4) in ·Nor:tllbrook to
deteoninc the appn>priateness of the existing speed J.imit.
The study results indicate the presetltly posted 40 mph speed limit is proper, but
is being violated by 81.4% of the observed vehicles. This infonnation is being
provided to assist you in your program to provide selective enforcement.
If you have qµcstions or need .additional information., please contact Lisa

Heaven-Baum. Traffic Studies Engineer. at{.847) 705-4l3S.
Very truly yours.
John P. Kos, P.E.

District En.gmeer
David A. Ziesemer, P .E.

Traffic Programs Engineer
Enclosure
kc: L. l~en--Ballm
R. Neubert
S:\Gcu\\VP\Sludiell\nc020521a.doc ~
123
A~-W
~
:Dlinots Department or
Division of Highways/Region One I District One
1ransportation
201 West Center Court/Schaumburg, llllnole 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
SST 3.3 (C) IL 43 (Waukegan Rd.)

\1arch 13, 2008
Chief Charles Wernick

Northbrook Police Department
140 l Landwehr Road
Dear Chief Wernick:
A traffic am.! engineering speed studv was cond:Jetc-d on {L 43 ~Wanke;an Rd.)

betw•~cn IL 68 (Dund.cc Rd.) and Willow Road in Northbrook to detenmnc the
appropriateness of the existing speed limit(s).
The study results indicate the presently posted 40 and 45 mph speed limit is
proper, but nre being vie lated by over 60% of the obscr:cd ·,chicles.
This i1,fo-rmalion is being prov1dcd to assist you in vour p1T 1 ~rr:n1 ;n p"'l ,i,:l: ·
seicct1ve ei1forccmenL
Copies of the speed data sheets have been enclosed for your infon11ation.
If you have questions or need addhonal information, pleas:.' contact f!.a<lger

Neubert, Data Collection Tedmiciar1 1 at (847) i05-409l.
Very tmly yours,
Diane M. O'Keefe, P.E.

Deputy Director of Highways,
Region One Engfrieer
hcc: Lisa Heaven-Baum

Rodger Neuoert
--fi_....1e -~-.,..;--~-----
-OD"
.Reading Copy
0:\0prTrl\KF\<;pecd Studies\lL 43_JL 68.doc
124
201 West <:enter <:ourt I Schaumburg. Illinois 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) Speed Studies - Sham,er Road
September 25, 2014
Mr. Charles J. Wernick

Chief
1401 Landwehr Road
Dear Chief Wernick:
A traffic and engineering speed study was conducted on Shermer Road from IL
43 to IL 68 to determine the appropriateness of the existing speed limit along
this section of highway.
The study results indicate the presenHy posted 30 mph speed limit to be proper
but also showed violation rate of 72.0 percent. Coples of the speed data sheets
have been enclosed for your information. This Information is being provided to
assist you in your program to provide selective enforcement.
If you have any questions or need additional information, please contact the
undersigned at (847} 705-4411.
Very truly yours,
John Fortmann, P.E.

Region One Engineer
By:
Cory Jucius, P.E.
Arterial Traffic Operations Engineer
Enclosures
125
~
'! ~a,.~·
··,.'., ?JI • • ~
n,,......,....u ......,,....t of Trransportation
I R;t I -
~
•:,, ......__.
Division of Highways I Region 1 / District 1

201 Wast Centur Court I Schaumburg, Illinois 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) Speed Studies: IL43 (Waukegan Road)
January 21, 2015
A traffic and engineering speed study was conducted on ll 43 {Waukegan

Road) from South oi Vottz toll 68 to determrne the appropriateness of the
existing 40 mph speed limit along this section of highway.
The study results indicate the presently posted 40 mph speed limit to be proper
and consistent with safe traffic flow but showed a violation rate of 44 percent.
This percent within the acceptable norm, selective entorcement by the police
department will not t>e requ1r.ed.
Our crash analysis included a review of the most recent crash data years from
2008 through available 2013. During this period there were a total of 159
crashes within this roadway segment. 39 of these crashes resulted in Injury
and 7 were classified as A-type or severe injury crashes. Predominant crash
types are Rear End, Angle and Sideswipe Same Direction type crashes. A
review of the. severe in_iury crashes found that excessive speed was not a
contributrng factor in these crashes. The. frequency and severity of crashes
within this segment is relatively !ow when compared to similar [ocatlons within
the District.
If you have any questions or need additional information, please contact Mr.
Hussain Mesyef, Arterial Traffic Operations Engineer, at 847-705-4381.
Very truly yours,
John Fortmann, P.E.

Region One Engineer
By:
Hussatn Mesyef, P.E.
Traffic Operations Engineer
Gen/ wp /arterial /correspondence I speed studies/ North cook/IL 43 Waukegan

Rd
126
Illinois Department of lransportation
Offict: of Highways Project hnplement.ation I Region 1 / District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 We!>l Center Court I Schaumburg, Illinois 60196-10%
RT 1 (C) IL 43 (Waukegan Rd}
May 18, 2017

Rr-: - .- .
I •-
The Honorable Sandra Frum -...

:,
Village President
Village of Northbrook
\225 Cedar Lane
Dear Village President Frum:
This is in response to your letter of May 2, 20'i 7 regarding the posted speed
limit along IL 43 {Waukegan Rd; from IL 68 (Dundee Rd) to Voitz Rd in the
Vlffage of Northbrook.
Speed limits on highways under the jurisdiction of the Illinois Department of

Transportation shall be established on the basis of the latest revisions/editions
to Chapter 11, Article VI of the Illinois Vehicle Code (IVC), the Illinois Manual on
Uniform Traffic Control Devices (MUTCD), the Standard Specifications for Road
and Bridge Construction, the Highway Standards and the Department's Policy
on Establishing and Posting Speed Limits on the State Highway Systern.
Section 11-601 otthe IVG spells out the statutory speed ~mits in eF~t ITT
Hlinois. Within an Urban Distnct, the posted speed limit ;s 30 mph. "Urban
District is defined in Section 1-214 of the lVC as "The territory contiguous to
and including any street which is built up with structures devoted to business,
industry or dwelling houses situated at intervals of less than 100 feet for a
distance of a quarter of a mile or more " Note that whether the street or
highway in question is inside or outside of the corporate 1tm1ts of a community is
not inciuded in this definition and is not applicable to the determination of where
such statutory speed appl,es. The structures referenced in the defmit,on
include only those that have direct vehicular access to the highway Structures
on both sides of the highway should be counted together in determining the
interval. The Department has verified that access points along IL 43 do not
meet the definition of an Urban Distnct Therefore, we are not allowed by law to
declare a statutory 30 mph zone along this section of IL 43
The IVC req..i,res that an engtneer,ng and trai~ic invest;gaticr; oo used as the
basis for posting any speed hmrt other than ttiose specified by statute. As
previously stated. we will conduct another speed study afong IL 43. The
Department will update the data required to complete this study including traffic
field observations and available crash history. You will be informed of the
results upon completion of the study.
127
Village President Frum
ivi a y i G. 2 C17
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Pogs ; v.1c.
If you have any questions or neec additional information please contact

me or fvis L,sa \-leaven-Baum. Ac!lng Bureau Cniet cf Trathc Operat:ons
a[ (cd7) 705-4,·;4'
Very tru'y yours.
Anthony J Quigley P E
r<eg1or, One E:n9ineer
128
Division of Highways/District 1
. ,. •
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST. 3.3 (C) IL 68 (Dundee Ave.)
January 23, 2001
Chief of Police
1401 Landwehr Road

c>< :.IJE~:- . J;/<::.,
As part of a periodic review program, a traffic and engineering speed study ,va.-i:
conducted on IL 68 (Dundee Ave-) from the [-94 east rnmp Jct. to wio--thc ...
Northshore R. R. overpass in Northbrook to determine if any revision in the
posted limit is \VlllTunted.
The study result<il indicate the present 40 mph speed limit should be lowered to
35 mph. Signing revisions have been ordered, and will be done as soon as our
work schedule ·\\-ill·allow.
The anticipated violation rate in the new 35 mph zone is 80 %. This information
is being provided to assist you in your program to provide selective
enforcement.
We are enclosing copies of the speed data sheets for ~our consideration.
If you have questions or need additional information. ple~e contact Lisa

Heaven-Baum, Trame Studies Engineer, at (847) 705-4135.
Very truly yours,
John P. Kos, P.E.

District Engineer
By
John A. Ci~hwurz., P.L
bee: J. Schwarz
L. Heaven-Baum
R. Neubert f f,r
S \Gen\WP•S1udics\prO IO I23bST J1•ct'
129
Illinois Department of 1tanspo~~ti9~
Division of Highways/District 1 •;, U:..J ·_- _··••. l• •
-C. ,.,. .• ...

201 West Center court/Schaumburg, fllinots 60196-1096 '
IH
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
1. ~-•--•-- ,,,.-.,,. ~----· ......

ST J 3 · (C) IL 43 (Waukegan Road)
May 21, 2002
Chief of Police
140 l Landwehr R",ad

·--- -~
--"' ... ... --·
,,.
A traffic and engineering speed study was conducted on IL 43 (Waukegan

Road) between Voltz Road and IL 68 (Dundee Road) in Northbrook to
detenuiuc the appropfialencSa of the existing, speea limit.
The study re.emits-indicate rhe presently posted 40 mph speed limit is proper. but
is being violated by 81.4% of the observed vehicles. This information is being
provided to assist you in your program to provide selective enforcement.
Copies of the speed data sheets have been enclosed for your information.
If you have quesi ions or need .additional infonnation, p'leas.e .contact Lisa
Heaven-:&~ Traffic Srudies Engineer. at (S47) 705-4135.
Very truly yours,
John P. Kos~ P.E.

District Engineer
~ -'~·-· . . .. . .
,,.~:r!.:&-1:-. . -~~.i, ,:.:. ; ~ o:.· ·~-•·..... '. ~ . , ' ... ; ' .... :.L'f.t
By
David A. Ziesemer, P.E.
•
Enclosure
bee: L. Heaven-Baum
R. Neubert ~
S:\uen\WP\Slullies\nc:020521 a.doc
130
.Illinois Department of lransportation
Division of Highways/Region One/ Olstrtct One
201 WestCenterCourt/Schaumburg, IIHnols 60196--1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
SST 3.3 (C) IL 43 (Waukegan Rd.)

March 13, 2008
Chief Charles We1nick
1401 Landwehr Road
Dear Chief Wernick:
A traffic and engineering speed study was conducted on IL 43 (Waukegan Rd.)
between IL 68 (Dundee Rd.) and Willow Road in Northbrook to detem1ine the
appropriateness of the existing speed limit(s).
The study results indicate the presently posted 40 and 45 mph speed limit is
proper, but nre being violated by over 60% of the observed vehicles.
This information is being provided to assist you in your progmm to provide

selective enforcement
Copies of the speed data sheets have been enclosed for your infonnation.
ff you hnve questions or need additional information, p lease contact Rodger

Neubert. Data Collection 1echnician1 at (847} 705-409!.
Very truly yo~
Diane M. 0 1Kecfe, P.E.

Region One Engineer
bee: Lisa Heaven-Baum

Rodgt..T Neubert
~2-G?Y-
-Reading Copy
0 :\0prTrf\Kf\.~d Sludies\lL .o_n. 68.doc
131
llfinois Department of ltansportation
Division of Highways/Region One/ District One
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) IL 43 Speed Studies
November 22, 2013
The Honorable Sandra Frum

Village President
Village of Northbrook .
1225 Cedar Lane
We have completed the speed study referenced in our June 27, 2013
letter for Illinois 43 from Dundee Road to Walters Road.
The results indicate that the posted 40 mph speed limit is proper and
consistent with safe traffic flow. The adjusted prevailing speed was
measured at 40.8 mph with a violation rate of 48.8 percent. Therefore, a
reduction in speed is not warranted.
If you have any questions or need additional information, please contact

Mr. Cory Jucius, Arterial Traffic Operations Engineer at (847) 705-4411.
Very truly yours,
John Fortmann, P.E.

Region One Engineer
bee: Steve Travia

Cory Jucius
...Don Chiarugi ·
Reading File
-·- · · -·-· 1=ne····- -· ·-----······ --
. S:\WP\ARTERIAL\CORRESp0NDENCE\NO COOK CO\IL 43 -s-o Voltz to Dundee Rd· no change.docx
132
Division of Highways/Region One-J District One
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court/Schaumburg, lllino,s 60196-1096
ST 3.3 (C) ll 9_
.: S eel Sruaes
November 221 2013
'·
Village President
1225 Cedar lane
We have completed the speed study referencBd in our ~lune 27 , 20,3

letter for i!inois ,.i3 from Dundee Road to Walters Road.
The results in,Jicate that '.he posted 40 m ph speed Hrnit is proper and
consistent with safe traffic ilow. The adjusted prevailing speed was
measured at 40.8 mph with a violation rate of 48.8 percent. Therefore, a
reduction in speed is not warranted.
It you have any questions or need additiona l informntion, please contact

Mr. Cary Jucius, Artenal Traffic Operations Engineer at (847) 705•4411.
Very truly yours,
John Fortmann, P .E.

Region One Engineer
By: ~///7
Stephen M. Travia , P.E.
Bureau Chief of Traffic Operations
bee: Steve Travia

Cory Jucius
Oen Chiarugi
Reading File
Fite
S ,Wf'-.AnTt:RIA •. CCRr• (S PONO[l\iCC\NO COOK CO·•L ~3 -so Voltz le-Dundee Rd no chang<.: aQcx
133
lllnois Department of 1ransportation
Division of Highways/Region One I Dl&trict One
201 West Center Court/Schaumburg, JH!nois 60196-1098
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) IL 43 Speed Studies
November 22, 2013

Village President
Vifla9e of Northbrook
1225 Cedar Lane
We have completed the speed study referenced in our June 27, 2013
letter tor lttin•ois 43 from Dundee Road to Walters Road.
The results indicate that the posted 40 mph speed limit is proper and
consistent with safe traffic flow. The adjusted prevailing speed was
measured a:t 40.8 mph with a violation rate of 48.8 percent. Therefore, a
reduction In speed is not warranted.
ff you have any questions or need additional information, please contact

Mr. Cory Jucius, Arterial Tra1fic Operations Engineer at (847) 705-4411.
Very truly yours,
John Fortmann, P.E.

Region One Engineer ·
bee: Steve Travia

Cory Jucius
. ·.Don Chiarugi ·
Reading File
·• File ··-· ...... ······- -
134
._
Illinois Department of Transportation

l&1 West -oenterrCourt.f Schaumburg, Illinois 60196-1096
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ST 3.3 (C) Speed Studies - Shermer Road
September 25, 2014
Mr. Charles J. Wernick

Chief
1401 Landwehr Road
Dear Chief Wernick:
A traffic and engineering speed study was conducted on Shermer Road from IL
43 to tl 68 to determine the appropriateness of the existing speed limit along
this section of highway.
but also showed violation rate of 72.0 percent. Coples of the speed data sheets
have been enciosed for your information. This information is being provided to
assi'st you in your program to provide sefectiye enforcement.
If you have any questions or need additional Information, please contact the
undersigned at (847) 705-4411.
Very truly yours,
John Fortmarm, .P .E.

Region One Engineer
By:
Cory Jucius. P.E.
Arterial Traffic Operations Engineer
Enclosures
135
llfinois Department of Transportation
201 Wast Center Court I Schaumburg, IIHnols 60196-1098
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
October 2-4, 2CU4
ST 3.3 (C) IL 43 (Waukegan Road) Speed Studies

RT 1 (C) Shermer Road

Htloois State .Representative
Fl§hteenlh Repiesentative Oistdct
820 Davis Street
Suite 103
Evanston, IL 60201
We have recej\ledyotJr October 9. 2014 letter regardfng-your eonstituenfs -

requests to reduce the speed hit on Waukegan.Road. from the cw:ren~
posted 40 mp-r,- limit and the proposed crosswalks on Shermer Road.
The Illinois Vehicle Code requires that an engineering and traffic investigation
be used as the basis for posting any speed limit other than those specified by
statute. The purpose of the study is to determine the speed limit that is
conslstent with motorist sa1ety.and with the .safe'ty of other necessary aetMties
_aiong:thehighway.
A speed study was completed on IL 43 (Waukegan Road} from south of Voltz

Road to Illinois 68 (Dundee Road) last November where the currently posted
speed limit was found to be proper and consistent with safe vehicular travel.
However1 the Department has scheduled a new speed study in whlch traff1C
. obsetvatians Viii& be made to provide information on the prevailing·speed of the
vehicles travemg on tllinois 43 aJong the subject limits. The appropriate speed'
limit(s) wm then t,e,determlned by considering addi'.tionat factors sach as
· · pedestrian activity, the number of intersecting streets and driveways; parking
· conditions, the most recent accident experience available to the Department,
and speed limits posted ori adjacent sections of highway.
- -
t his study to be oompfeteC!l-by !t,le end of ~

We anticipate _ ,Md we wi4I
let you know the .results of our investigatior1 at tha1 time. -
In regards to the proposed crosswalks along Shermer Road between Dundee

and Waukegan Roads, the Village of Northbrook needs to complete their
~--------- ________ _ _________________s_idewaJk __sy_s.tem..along Shermer.Road. In addition, tbe_V:illage_wauld be ___ ...... _
- responsible for securing a permit from the Illinois Department of Transportation
(IDOT) to if!stall ADA compliant ramps and pads at the pr~posed crossings and
they would also be responslbJe tor .painting· an(f maintalning the. proposed
cmsswa1k makings. -
136
Representative Ga~el
October 24, 2014
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Page Two
Once these improvements are made, IOOT would install and maintain any
supplemental pedestrian crossing warning ·signs. The Village of Northbrook
should contact Mr. Jonathan Karabowicz, Area Permits Engineer, at (847) 705·
4149 to initiate the·pem,lt process.
H you have any questions or require additional information,. please contact Mr.
Hussain Mesyef, Arterial Traffic Operations Engineer, at (847) 705-4138.
Very truly yours,
/h~
;z;-Fortmann. p .E.
Deputy Olrector of Highways
Region One Engineer
- -••-'• - ••••-••• --••• • - -••-••--• - •-••• ---••••-• - • - • • - - • - • ••- • •- -•-•••w

.. -- ··-·- -·--•·- ----- - -·-----·-·•~·••····-··· . - - - - .
137
This letter In response to your request on September 16, 2015 concerning the speed limit on IL
43 from Volts to IL 68 in Northbrook,
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
in regards to the village speed reduction requests. As you are aware off, the speed limit policy is
a data driven and without tile SllP!J)Oltive data -h can't be change, the speed fimit is the law and
by the Illinois Vehicle Code requires .that an engtnearl.ng and traffic investigation be used as the
basis for posting any speed limit other than those specified by statute. The purpose of the study
Is to determine the speed limit that is consistent with motorist safety and with the safety of other
necessary activities along the highway.
The Department has conducted four speed studies on this secti9n of the roadway in the last two
years; an r.esults indicate the Dtresently posted 40 mph,. speed limit to,be oroper and consistent
with safe traffic flow. Therefore, changing the speed Dmit fs r:tot warranted at this time. We wilt
continued to monitor this segment of the roadway, should the existing conditions are changed in
the future.
The department has·also ·reviewed the existing conditions and available 5-year crash history for
the subject location, the examination of the five year crash data for this segment found that the
severity and the fr:eq.uency and severity of crashes within this segment is relatively Jow when
oompared to similar .locations Within f.he District. Therefore. this segment is not 5% accident
Jocatioo to qualify for additionat adjustments; furthermore the analysis shows that the majorities
of the accident reported with in this segment are at the major signalized Intersection mostly rear
end -and side . swap collisions. The second majority at the front of Mobil Gas station, my
understanding that closing the Mobil driveway near the traffic signal on IL 43 are currently
under review by the department.
The pedestrian activates along this segment are very minima.t, it& appeaxed that most of the
pedestrians- traffic is not along the tl 43 but rather across, at controlled signalized intersection, ' ''""Iii
shermer Rd has been updated with four push button and pedestrian heads. While the number of
the pedestrian does not qualify the segment for reduction factored, a five percent factor was
applied In the field data calculations, which did not have any significant effect on the outcome of
the study.
Excessive speeds are a matter better handled through enforcement efforts rather than posting of
restrictive regulations. Posting a speed 4iroo lower than what a substantial cross section of
drivers considers appropriate does not significantiy affect prevailing vehicle speeds.
Responsible drivers tend to adjust to road conditions encountered. Posting a significantly lower
speed limit creates more violators but does not actually provide additional safety. We will
continue to monitor this location in the future when the existing conditions of the roadway are
changed and make additional studies as needed.
Please see the attached speed calculation summary sheet and fietd data collected in the most
recent completed
•.
study.
138
Illinois Department of ltansportation
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court/ Schaumburg, Illinois 60196-1096
ST 3.3 (C) Speed Studies: IL43 (Waukeg~n Road)
January 21, 20~5
~2
Dear : l'/'t-1' ,I tV ~ e-
A traffic and engineering speed study was conducted on. tl 43 (W~egan

Road) from South ot Voftz to fl 68 to determine the appropriateness of the
existing 40 mph speed limit along this section of highway,
and consistent with safe traffic flow but showed a violation rate of 44 percent.
This percent within the acceptable norm, selective enforcement by the police
department wm not be reqwred.
Our crash anatysis included a review of the most recent crash data years from
2008 through available 2013. During this period there were a total of 159
crashes within this roadway segment. 39 of these crashes resulted in injury
and 7 were classified as A-type or severe injury crashes. Predominant crash
types are Rear End, Angle and Sideswipe Same Direction type crashes. A
review of the severe injury crashes found that excessive speed was not a
contributing factor in these crashes. The frequency and severity of crashes
within this segment is retattvety Dow when compared to simifar Jocations within
the District.
If you have any questions or need additional information, please contact Mr.
Hussain Mesyef, Arterial Traffic Operations Engineer, at 847-705-4381.
Very truly yours,
John Fortmann, P .E.

Region One Engineer
By:
HussainMesyef, P.E.
Traffic Operations Engineer
Gen/ wp /arterial /correspondence I speed studies/ North cook/I 43 Waukegan

Rd
139
Office of Highways Project Implementation / Region 1 / District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court I Schaumburg1 Illinois 60196-1096
RT 1 (C) IL Route 43 General
July 22, 2016

Illinois State Representative
Eighteenth Representative District
820 Davis Street, Suite 103
Evanston, IL 60201
This is a follow up response regarding the Road Safety Review (RSR) along
IL 43 (Waukegan Road) from Interstate 94 to Willow Road. We have received
the fina1 RSR report and are in the process of addressing the recommendations
within the report.
The following are near term countem,easures that can be implemented using
our internal forces and are currently being addressed.
• All signs in the corridor will be examined and replaced if found to have
reduced reflectivity.
• The position of the signal ahead warning sign and flashing amber
beacon for northbound IL 43 and Voltz Road ·will be evaluated to
determine if it can be relocated to provide more advanced warning of
the intersection. If the assembly cannot be relocated, the Department
will consider installing reflectorized backplates to the signal heads to
increase signal conspicuity.
• Advanced 1ntersection warning signs at Thomwood lane and at
Interstate 94 Frontage Road and advanced driveway warning signs
between Shemier Road and Maple Avenue will be evaluated and placed
if feasible.
• Reflectorized backplates will be installed on the signal heads at IL 43
and Interstate 94 South Ramp Junction.
• Traffic signal system needs and timing witt be reviewed to determ1ne if
any changes are needed.
• We will conduct foliage clearing through the corridor to increase visibility
within the corridor.
• 1heDeparonent nas modified tne pavement mancmg plans for the

current resurfacing project along IL 68 at IL 43 to offset the left tum
lanes to provide better visibUity for opposing left turnmg vehicles on
IL 68.
140
Representative Robyn Gabel
July 22, 2016
Page Two
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
The following recommendations are those that require additional study or

coordination with the Village of Northbrook. Identification of a funding source
may be required as these actions may not currently be included in the
Department's FY 20 17~2022 Proposed Highway Improvement Program.
• The Department will conduct an investigation on modernizing the

existing signals along IL 43 to current standards at the intersections of
IL 68, Shermer Road, and Walters Avenue.
• The Department will evaluate the existing guardrail along the east side
of IL 43 north of Kamp Drive and evaluate the replacement of guardrail
end terminals.
Funding has not been identified for these actions. However, the Department
will consider funding as part of future programs including alternative funding
sources such as the Highway Safety Improvement Program (HSIP) or
Congestion Mitigation and Air Quality (CMAQ) program.
The Village of Northbrook is responsible for the maintenance and placementof

stop bars and crosswalks. The Department will coordinate with the Village for
the possible relocation of side street stop bars and installation of high visibility
crosswalks at the signalized intersections along IL 43.
The following countermeasures woutd reqttir~ a more detailed engineering

study and are considered long term needs. Funding is not included in the
Department's FY 2017-2022 Proposed Highway Improvement Program for
engineering or construction. Our Department monitors various conditions along
State highways and identifies improvement needs as warranted. These long
term needs will be included in our priorities for future funding consideration
among similar improvement needs throughout the region. Additionally, the
Department will give consideration to alternative funding sources such as
Highway Safety Improvement Program (HSIP) or Congestion Mitigation and Air
Quality (CMAQ) funds.
• The Department can consider studying the modification of the existing

cross section from two lanes in each direction with no median to two
lanes in each direction with a median to provide left turn channelization.
This would include a dedicated northbound left turn lane at the
intersection of IL 43 and Maple Avenue.
• Consideration will be given to converting the northernmost driveway of
the Mobile Gas Station on the southeast corner of IL 43 and Shermer
Road to a right in/right out configuration and modifying the southwest
comer to provide better visibility of pedestrians.
- -· ·----·----··--"·---··-···---·-·· ------ ---- -· - . --·------ ·----·-- - - -- ·---·-- --------- ·--- --------- -·- --.. ---- ..
• Drainage through the corridor would also be considered in any long term
study and locally responsible items such as sidewalk and lighting
modifications can be coordinated with the Village of Northbrook.
141
Representative Robyn Gabel
July 22, 2016
Page Three
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
The Department is available to present the RSR recommendations and

measures to be implemented by the Department. Please contact Lisa Heaven-
Baum at (847) 705-4141 to schedule a meeting time.
If you have any questions or need additional information, please contact me or

Mr. Daryle Drew, Traffic Signal Engineer, at (847) 705-4424.
Very truly yours ,
!} F ~.z;:;,., /74,?
Jo~ ; ;_
Region One Engineer
cc: Sandra Frum
142
State Representative Robyn Gabel Mail • FW; Waukegan Road in Northbrook speed limit • concern for pedestrlansl-Rep Gabel 9/16/15, 11:00 AM
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FW: Waukegan Road in Northbrook speed limit - concern for pedestriansl-Rep

Gabel
Phelps, Julle K. <Julie.Phelps@illinois.gov> Wed, Sep 16, 2015 at 8:27 AM

To: Karen McCormick <karen@robyngabel.com>
Karen-
This is in response to the request of reducing the posted speed limit on IL 43 (Waukegan Road) between Shermer
and Voltz Roads in the Village of Northbrook.
The Illinois Vehicle Code requires that an engineering and traffic investigation is the basis for posting any speed
limit other than those specified by statute. The purpose of the study is to detennine a speed limit that is
consistent with motorist safety and with the safety of other necessary actjvities along the highway. Traffic speed
observations are made to provide information on the prevailing speed of vehicles traveling on a section of
roadway. The appropriate speed limit is then determined by considering additional factors such as pedestrian
activity, the number of intersecting streets and driveways, parking conditions, crash experience and the speed
limits posted on adjacent sections of highway. The Department has conducted three speed studies on this section
of the roadway in the last two years, all results indicate the presently posted 40 mph speed limit to be proper and
consistent with safe traffic flow. Therefore, changing the speed limit is not warranted.
Excessive speeds are a matter better handled through enforcement efforts rather th.an posting of restrictive
regulations. Posting a speed limit lower than what a substantial cross section of drivers considers appropriate
does not significantly affect prevailing vehicle speeds. Responsible drivers tend to adjust to road conditions
encountered. Posting a significantly lower speed limit creates more violators but does not actually provide
additional safety. We will continue to monitor this location and make additional studies as needed.
The department has also reviewed the existing conditions and available 5-year crash history for the subject
location. The frequency and severity of crashes within this segment is relatively low when compared to similar
locations within the District.
!------------------- ----------- ·-· -------- ·--- -- --· ·- -----··· ·-· ------·

Please let me know if I can be of further assistance.
Respectfully-
httpa;//mail.google.com/mall/u/0/?ul.,2&Ik=371 f80fbb9&vlew=pt&aearch=lnbox&th=14 fd65 71a0f238a3&slml=14fd6571 a0f2 3Ba3 Page 1 of 4
143
Illinois Department of Transportation
Office of Highways Project Implementation / Reglon 1 / District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court I Schaumburg, IHfnofs 80196~1696
RT 1 (C) I~ 43 - General
November 9, 2016 .
The Honorable .Sandra Frum

Vtttage President
1225 Cedar Lane
Northbrook, .IL 69062
Dear VDlage President Frum:
a
This is foilow up to our August 26, 2016 meeting summarizing the findlngs of
the Road Safety Rev1ew conducted 'along l'L 43 {Waukegan Rd) from Interstate
94 to Willow Rd located In the Village of Northbrook. ·
l The Department annually reviews statewide crash data to identify •

approximately 5% of all roadway locations within .the State of Illinois with the
greatest potential for safety improvement (PSI). · The process identifies those
. locations experiencing a higher severity .of crashes when compared to simflar
locations statewide based on the latest available crash data..for & s;.year perlod.
Additionally, locations that are not 5% locations but do have a positive PSI are .
grouped into safety tiers. These tiers are ranked as high, medium, low or
marginal. High tier locations are those that are not 5% locations but faH within
. the highest .10% positive PSI.' Medium tier locations are those that are riot 5%
or high tier but fall within the top 25% posltfve PSI. Low tier locations are those
. that are not 5%, high or medium tier but fall within the top 50% of positive PSI. .·
·.. All remaining locations not in the 5%, high, medium or low tiers are considered
marginal tier. ·
Within the IL 43 corridor, for the 2009 and 2014 period, there were 430
recorded crashes with 65% of those crashes occurring atintersections. 29% of
crashes resulted in an injury with the majority classified either as a non-severe
.
. ·. I . .. injury ~rash or.an injury is reported but not evident to the police officer.. There is
·one identified 5% segment along IL 43 from approximately 180 feet north of the .
Interstate 94 north junction with IL 43 to 1,400 feetnorth of the Intersection of IL · ·
43 and IL 68 (Dundee Rd). The intersection of ll 43 and Maple Ave is
Identified as a low safety tier intersection and the Intersection of IL 43 and
Willow Rd Is considered a medium safety tier intersection.
Crash ~te analysis Is another effective comparison of relative safety. Crash

------:--- ··-···--.... ___rate allow$ for evaluatiQn of segments of similar road ·typecuHactors e-xposure·-c·-
.such as traffic volume and length of.roadway segment into the comparison. In
.general, the IL 43 comdor is experiencing a ~ower fatal and severe injury crash
. rate than the statewide average for similar facilities. · ·
144
November 9, 2016
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Page Two
The statewide averages for Other Principal Arterial routes such as IL 43 are
0.409 fatal crashes and 4.666 severe injury crashes per one hundred million
· vehicle miles traveled (HMVMT). No fatal crashes occurred during the analysis
time period and the calculated. severe injury crash rate of 4.260 crashes per
HMVMT is below statewide average. There were no Identifiable·patterns or
specific spot location experiencin9 an overrepresenta\lon of severe injury
crashes in the corridor. Rear end crashes were the predominant crash type in
the corridor representfrig 50% of total crashes and 56% of injury crashes.
Excessive speed was not found to be ·a contributing factor In crashes within the
corridor. _Speed studies have been conducted. The purpose of these studies Is
to establish a posted speed Omit that the majority of pubDc will voluntarily obey.
These studies give consideration to such factors as pedestrian activity, the
· · number of intersecting streets and driveways and previous crash history, The
existing 40 mph speed limit posted from north of IL 68 to south of Voltz Rd was ·
determined to be appropriate. The adjusted prevailing speed was ·measured at
. .39 mph with an observed violation rate of 40% .. The 4S mph speed limit posted
·from north of Interstate 94 to _north of IL 68 was also reviewed. The adjusted .
prevailing speed was measured at 39 mph with an observed violation rate of ·
3.2%. Therefore, the Department recently reduced to.45 mph zone north of IL
6a {Dundee Rd} to 40 mph. The sign revisions have been made.
The location experiencing the highest number of overall crashes in the corridor
· Is the signalized interse.ction of IL 43 (Waukegan Rd) and IL 68 (Dundee Rd).
During the analysis period, there were 147 recorded crashes at the intersection
·or 34% of total crashes in the corridor. Rear erid crashes were the most
. predominant crash·type·followed •by left turning crashes. As part of.the recent
resurfacing project atong IL 68, the Department has modified the_pavement . .
markings for the east/west bound left tum lanes on ll 68 to Increase visibility of
. opposing vehicles. The Department hes also identified the ·m,ed to modernize
the existing IL 43 at IL 68 traffic signal which wlll increase visiblllty. Funding for
this modernization is not currently includ~d in the Department's Proposed FY
17-22 Highway Improvement Program. We will continue to monitor this location
for consideratlon as part of future funding programs. .
. .
to
With.regard the lnterseC\lon of lL 43 and Maple Ave, the Intersection is not · ··
identified as a high severity crash location. . A review of the existing traffic
-counts and recent property damage only crashes support the .need for the
addition of a northbound left turn fane along IL 43. Roadway widening would be
needed from south of Walters Ave to north of Voltz Rd to match the existing IL
. 43 cross section. Preliminary engineering will be needed to evaluate right of
.--"-'--- -· ~--- --:---- -~-------way-and-environmental-Impacts of widening ;· We-have:initlated -a-prellm lnary - - -- ·.
· ·- engineering study. Funding for phase II design or phase Il l construction has
not been Included in thecurrent FY 17-22 Highway Improvement Program but
,.--... wlll be consider in future programs.
145
November 9, 2016
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Page Three
Regarding the Mobile Gas Station driveways along IL 43 south of Shermer Rd,
the location ls not identified as a high severity crash location. The
Department's records indicate that the driveways were installed under highway
permit. Consideration of any access restriction would require preliminary
engineering at this location and woYld consider numerous .factors 1ncludlng ·
traffic volumes as well as crash experience, environmental constraints and
resources, and ultimately an evaluation of impacts, benefits, and costs. The
result may not necessarily be limited to restricting left turn access to this
specific driveway, especially If other needs or solutions.are identified. This
would involve coordination with stakeholders in the area Including business
owners and residents. Due to fiscal constraints, the Department has been
required to focus and .prioritize our limited resources on safety improvements as
well as pavementand bridge rehabilitatton . As such funding for an
improvement at this location is currently not included in the Department's FY
17-22 Proposed Highway Improvement Program.
If you h~ve any questions or need additional information, please contact me or

Ms. Lisa Heaven-Baum, Acting Bureau Chief of Traffic Operations, at (847}
705-4141 .
Very truly yours,
/1//4;1~
Jln':rtmann, P.E.
Region One Engineer
cc: State Representative Robyn Gabel

Matt Farmer - Village of Northbrook
---- ~--- --- .- -- -• --- ---···---- ·· -···---·-··-· -~ ---, --·--- . -- . ---- - .--- -- .
146
. Illinois Department of lransportation
·-
'
Office of Highways Project Implementation / Region 1 I District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 W85t Center Court I Schaumburg, Illinois 60196-1096

RT 1 (C) IL 43 RECEIVED
April 14, 2017
APR 21 2017
VILLAGE OF NORTHBROOK
Village President VILLAGE CLERK
1225 Cedar Lane
This is in response to your letter of March 27, 2017 regarding the posted 40
mph speed limit along IL Route 43 (Waukegan Road) from IL Route 68
(Dundee Road) to Voltz Road in the Village of Northbrook.
The Illinois Vehicle Code requires that a traffic engineering investigation be

used as the basis for posting any speed limit other than those specified by
staMe. The purpose of the study is to determine the speed limit that is
consistent with motorist safety and with the safety of other necessary activities
along the highway. Traffic speed observations will be made to provide
Information on the prevailing speed of vehicles traveling on this section of
highway. The appropriate speed limit will then be determined by considering
additional factors such as pedestrian activity, the number of intersecting streets
and driveways, parking conditions, crash experience and speed limits posted
on adjacent sections of highway. The Department will conduct a speed study
for this section earty this summer based on our current workload. We will
infom, you of the results upon its completion.
With regard to the proposed improvement of IL Route 43 atMaple Avenue, the

Department has initiated data collection for the preliminary engl_n ~ring
process. Letters requesting project development information and notifying
project stakeholders of the initiation of engineering study were sent to tltt ·1
Village of Northbrook on March 27, 2017. This improvement is not currently
included In the Department's FY 2017-2022 Proposed Highway Improvement
Program. However, this project will be included in our priorities for future
funding consideration among similar Improvement needs throughout the region.
Please let us know if you have any questions or need additional infonnatlon
concerning this improvement.

Lisa Heaven-Baum, Acting Bureau Chief of Traffic Operations, at (847) 705-
4141.
Anthony J. Quigley,
Region One Engineer
147
Office of Highways Project Implementation I Region 11 District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court I Schaumburg, Illinois 60196-1096
RT 1 (C) IL 43 (Waukegan Rd)
May 18, 2017

RE "'.-' ' ED
VIiiage President MAY - . 01
VILLA .. ROOK
1225 Cedar Lane V1LlAu UERK
This is in response to your letter of May 2, 2017 regarding the posted speed
limit along IL 43 (Waukegan Rd) from IL 68 (Dundee Rd) to Voltz Rd in the
Village of Northbrook.
Speed limits on highways under the jurisdiction of the Illinois Department of

Transportation shall be established on the basis of the latest revisions/editions
to Chapter 11 , Article VI of the Illinois Vehicle Code (IVC), the Illinois Manual on
Uniform Traffic Control Devices (MUTCD), the Standard Specifications for Road
and Bridge Construction the Highway Standards and the Department's Policy
on Establishing and Posting Speed Limits on the State Highway System .
Section 11-601 of the IVC spells out the statutory speed limits in effect in
Illinois. Within an Urban District. the posted speed limit is 30 mph. "Urban
District" is defined in Section 1-214 of the IVC as "The territory contiguous to
and including any street which is built up with structures devoted to business,
industry or dwelling houses situated at intervals of less than 100 feet for a
distance of a quarter of a mile or more ." Note that whether the street or
highway in question is inside or outside of the corporate limits of a community is
not included in this definition and is not applicable to the determination of where
such statutory speed applies. The structures referenced in the definition
include only those that h?tve direct vehicular access to the highway. Structures
on both sides of the highway should be counted together in determining the
interval. The Department has verified that access points along IL 43 do not
meet the definition of an Urban District. Therefore. we are nptallowed by law to
declare a statutory 3.Qmph zone along this sectioo of It. 43,
Tb.e JVC r.ec;iui(e& hat an e gioee1in9 and-tratfto in~tigation be- used a~ thtt
basis for posting any speed limit other fhan those specified by statute. As
previously stated we will conduct another speed study along IL 43. The
Department will update the data required to complete this study including traffic
field observations and available crash history. You wm be informed of the
result& upon completi n of lhe stody.
148
May1 8, 201 7
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Page Two
If you have any questions or need additional information . please contact

me or Ms. Lisa Heaven-Baum Acting Bureau Chief of Traffic Operations
at (847) 705-4 141
Very truly you rs /
Anthony J. Quigley P E
Region One Engineer
cc Pri scilla T ob1 as
149
Illinois Department of ltansportation
Office of Highways Project Implementation / Region 1 / District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center Court l Schaumburg 1 lllfnots 6(>196~1096
nT 4 ,.,,..\ ti
'''
• ., n"'-····--an n--d'
I \VJU-~v\YVCIUl\.el,f 11'\Vc:I}
locai: Northbrook
May 30, 2017
Mr. Larry A Hewitt, Ed.D.

S1.,permtendent of Schools-
Northbrook School Distric1 28.
1475 Maple Avenue
Dear Mr. Hewitt:
We have received your May 3, 2017 ietter regarding _your request to consider
the posting of a 20 mph Schoo1 ~ed Zone along .the segment of 4L 43
(Waukegan Road) from Walters Avenue to Maple Avenue. This request is
predicated due to the number of students who must cross Waukegan Road to
access Meadowbrook Ele.mentary and Northbrook Jr. High School.
Sd1uui :sµet:Hi iimihs ur1 itighwc:1y::; urn.ier ihe jurisdiuiiun uf lhi:s Dttparlrnt:mi c1rt,
established based on an engineertng and traffic investigation conducted by our
forces to determine whether or not a school speed zone is warranted. The
investigation considers such factors as the existing traffic controJ~ whether
school crosswalks are present or not, and where the chitdren wollfd be tocated
in relation to the traffic.
School zones should not be established tor crossings where school children are
protected by devices such as stop signs or traffic signals. An exqeption may be
made when the speed zone serves to protect children walking on or
immediately adjacent to the roadway in the schoo4 area.
Our investigation has determined that there are signatized intersections to allow
children to cross Waukegan Road at Walters Avenue and at Voltz Road.
Consideration for crosswalks traversing Waukegan Road at Maple Avenue
would not be considered since this intersection Is not controlled by signals or
stop signs and does not continue east of Waukegan Road. The roadway
¾~~Y1 -~~":-!{ ffl'l:'.'~'°.$ <11'.;i't.'IS~ for .the: .residents who live east oj Waukegan Road
to the subject schools funnets trave~rs lo the signalized witersections of either
Walters Avenue to the north or Voltz Road to the south. Additionally, there is
approximately a 20 (twenty) foot parkway along ·IL ·43 that -provides a buffer
between the school children and the motorists.
Thefefor.~.., .'YR-~~~ ~t:F.i~~ft st!=:~,.:nr-.Qr~c.tf\ct~h•t.ttJ~. !=!Jf:1,!1,~~i7...:~-. !nf.~!"~~!·:t~~ ~rl

0
by rhe wide parkway, a schooi speed iimit is not warramed aiong the subject
segment of vVaukegan Road.
150
Mr. Hewitt
May 30, 2017
Page Two
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
In regards to the reoently requested speed fimit reduction to 30 mph along

Waukegan Road, the Department has recently responded to Northbrook VIiiage
Presideot, Sandra Fr.Jm, h dicati'ig !hat the swject AJegment of Waukegan
Road cannot be posted as a statutory 30 mph speed zone. We have, however,
scheduled a speed study to review existing 40 mph speed.
The Department has initiated a proposed Improvement of IL 43 at Maple

Avenue to add a northbound left lane on IL 43. The Department has begun
data ccillectlon fer the ?f'8li!nir.ary engineering process. This improvement :s
not currer:tiy included in the Department's FY 2017-2022 Proposed Highw~y
Improvement Program. However, this project will be inciuded :n our priorities
for future funding consideration among similar improvement needs throughout
the region.
If you have .any questions or require additional information, please contact me

or Ms. Usa Heaven-Baum, Actino Bureau Chief of Traffic Operations, at (847)
70'5-4141.
151
IDino1s Department of 1ransp.ortation
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Office of Highways Project Implementation I Region 1 / District 1

201 West Center Court/ Schaumburg, Illinois 60196·1096
RT 1 (C) IL 43
August9,2017
The Honorable Sandra. Frum.
Village President
1225 Cedar Lane
Dear ViUage President Frum;
This is a fo61ow up·to our Jetter of Apn114, 2017 regarding the posted speed
ftmtt.:a1ong m.. 43 ootween fl·68 and sowth ,of Voltz Road ·in the ViRage of
Northbrook.
The Department has completed an engineering investigation of the posted
speed limit on this section of the highway. The results indicate that the posted
40 mph speed limit is proper and consistent with safe traffic flow. The adjusted
prevailing speed was measured at 40.8 mph with an obseived 4S-.3- p-ercent
vlolatlof'!I rate. Thevefor;e, m.o change in the postep i!i?eed llrrut is wa.nanted at
this trme.
Experience has shown that posting a speed lower than what a substantial cross
section of drivers considers appropriate does not significantly affect prevailing
vehicle speeds. Responsible drivers tend to adjust to road conditions
encountered. Posting a significantly lower speed limit creates more violators
but does not actually provide additional safety. We will continue to monitor this
locatic>J\.,aTTd mruQe.-additionai srud.ies-as needed when .the oondttions
slgni«:anbly changje.
Mr. Hussain Mesyef, Traffic Operations Engineer, at (847) 705-4156.
Very truly yours,
(2~ 4/l-,/,J-
Anthony J. ~ig~y. f!.E.
Region One Engineer
152
lfmois Department of lranspartation
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Office af Highways Prdjita fmplamentalion f Ri!Qfcn 1 J Ofstr:fct 1

201 West Center Court I Schaumburg, IUinols 60198-1098
RT 1 (C)1L 43
Augus1 9, 2017
Village President
ViOagie of Nor1hbrook
1225 Cedar Lane
Nortnbrook, ll 60062
This ls a foffow up to our Jetter of April 14, 2017 regarcr111g the poslBd speed
limit elong ,fl. 43 between ~ :ea and .south of Vo"ftz ·Road in ·the Village of
Northbrook.
The Department has completed an engfneertng lnvestlgetion of.the posied
speed limit on this section of the tiighway. The resu«s indicate that the posted
40 mph speed limit Is proper and consistent with safe traffic flow. The adjusted
prevailing speed was measured at 40.8 mph with an observed 48;3 percent
vlolaflon rate. Therefore, no change- ln the·posted speed lfmlt fs warranted at
--, this tlme.
Experience has shown that posting a speed lower than what a substantial cross
sectron o1 dtfvers.considers approprief.e does not sig.ntftcaniiy affect prevailing
whk:le ·speeds, Responsible drtvers tend to adJusttoroad concJtttons
encountered. Posting a s~ntiy·lower speed Umi creates more vtolators
but does not actually provide additional safety. We wlll oontinue to monitor this
.toc::atlon and maM additiona4 studies as needed when the conditions
slgnlflct!Tlfly cl'lenge.
If you have any questions or need additionaJ information, ptease oontact me or
M'. Hustaln Meeyef, Traffic Operaaans.E ngh,er, a:t (847) 705-4156.
Very truly youn;,
/i!rtt:fi,;J
Region Ona Engineel'
153
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 6
US DOT NHTSA BICYCLIST AND
PEDESTRIAN SAFETY
154
BICYCLIST AND PEDESTRIAN SAFETY
Crashes involving ,. In the United States. the number of traffic crashes involving a bicyclist
a bicycDst or
or pedestrian has been increasing since 2009. In 2017, there were 5,977
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
pedestrian have
been increasing pedestrians and 783 bicyclists killed in motor vehicle crashes.
•• There are three categories of issues that contribute to traffic crashes involving bicyclists
ofc/i 2N
009 and pedestrians: motorist behavior. non-motorist behavior. and infrastructure. Some of
the issues overlap between categories.
• Motorist behaviors include speeding, distraction. lack of traffic law awareness,

non-compliance with traffic laws. and alcohol or drug impairment.
EVERY
• Non-motorist (i.e., pedestrian and bicyclist) behaviors include tack of traffic law
awareness, non-compliance with traffic laws, poor conspicuity, and alcohol or
other impairment. ml
ZS u
• Infrastructure issues include inadequate separation between motorists and 1 pedestrian is injured
in a traffic crash.
non-motorists, lighting. and signage o r crosswalks.
The P r o b l e m s - - - - - - - - - - - - - - - - - - - - - - - - - - - - .
Poor compliance with traffic laws and Improper use of faclUtles: Drivers. pedestrians. and
bicyclists are safer when they comply with traffic Laws and correctly use roadwa>J facilities.
Common noncompliance includes motorists failing to yield; pedestrians and bicyclists
failing to .foUow traffic S4gns and signals; and walking or ndmg in improper locations such
as the wrong side of the road. These issues are often due to poorly designed facilities or
misunderstanding of traffic laws/devices.
Speeding: When speeding, drivers increase the risk for a collision with a bicyclist or
pedestrian. The likelihood of a pedestrian dying from a coltision wtth a motor vehicte
increases from 8 percent at 31 mph to 50 percent at 47 mph.
Inadequate separation: Bicyclists and pedestrians ate safer when they are separated from motor
vehicles. When facilities are inadequate, there is dense traffic, or visibility is limited, pedestrians
•
tr• might wattc in the roadway or cyctists may opt to ride on sidewalks or against the direction of
traffic. All of these behaviors increase the chances of a crash.
Bicyclists ao •
and pedestrians are i Cl'OSSing locations: The !iketihood of a crash increases when pedestrians and bicyclists
cross at locations not designed for crossing. Almost one-fifth (18%) of pedestrians killed
safer when separated
from motor vehicles. and 30 percent of bicyclists killed were struck in intersections. Figures are greater in
urban settings where crossing density is higher.
Inadequate conspicurty: When drivers can·t see bicyclists or pedestrians, whether in light
or dark conditions, a crash is more likely. Three-fourths (75%) of pedestrians killed and 45
percent of bicycUsts killed in 2016 were struck in dark conditions. Many States have laws
that require bicyclists to use lights/reflectors when traveling at night.
Impairment and distraction: Drivers, bicyciists, and pedestrians who are impaired
killed were struck by
-by alcohol or drugs-or distracted all increase the likelihood of a crash. drivers in dam conditions
Who's At Risk
About 70 percent of those killed in traffic crashes are male, and injury rates are higher for males than for females. In 2016,
the average age of pedestrians killed in traffic crashes was 47, and the average age of cyclists kilied was 46. Both numbers
have increased over the last 10 years.
Sources: Fatality AnalysJs Reporting System, NHTSA (2013, 2016 fact sheets); Rosen, E., & Sander, U. (2009). Pedestrian fatality risk as a function of car impact speed. Accident Analysis &
Prevention, 41 (3), 536-542.
155
BICYCLIST AND PEDESTRIAN SAFETY
Resources for States and Communities
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
NHTSA Bicycle Safety page: www.nhtsa.gov/road-safety/bicyclists

NHTSA Pedestrian Safety page: www.nhtsa.gov/road-safety/pedestrian-safety
Traffic Safety Facts, Pedestrians: https://crashstats. nhtsa.dot.gov/Api/Public/ViewPublication/812493
Traffic Safety Facts, Bicyclists: https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/812507
The Pedestrian and Bicycle Information Center: www.pedbikeinfo.org
Countermeasures That Work (9th Edition, 2018, Chapters 8 and~: www.Mtsa.gov/sites/nhtsa.dotgov/
files/.documents/812478_v5_countermeasures-that-work-a-hrghway-safety-countermeasures-gutde-
9thedition-2017.pdf
Advancing Pedestrian and Bicycle Safety: A Primer for Highway Safety Professionals: www.nhtsa.gov/sites/
nhtsa.dot.gov/files/812258-peds_bike_primer.pdf
Pedestrian and Bicyclist Data Analysis (Research Note): www.nhtsa.gov/sites/nhtsa.dot.gov/files/
documents/812502_pedestrian-and-bicyclist-data-analysis-tsf-research-note.pdf
The Effect of High-Visibility Enforcement on Driver Compliance With Pedestrian Right-of-Way Laws:
FoW'-Yeat Follow-Up: www.nhtsa.gov/s1tes/rihtsa,dot.gov/fi1es/docurmei!'lts/812364_
highvisibitityenfdrivercomppeds4yearfottowup.pdf
Effect of Electronic Device Use on Pedestrian Safety - Literature Review (Phase 1):
www.nhtsa.gov/sites/nhtsa.dot.gov/files/812256-effectelectronicdeviceusepedestriansafety.pdf
2012 National Survey of Bicyclist and Pedestrian Attitudes and Behaviors Database:
• Volume 1 - Summary Report: www.nhtsa.gov/sites/nhtsa.dot.gov/fi1es/81184la.pdf
• Volume 2 - Findings Reports: www.nhtsa.gov/sites/nhtsa.dot.gov/files/811841b.pdf
• Volume 3 - Methodology Report: www.nhtsa.gov/sites/nhtsa.dot.gov/files/811841c.pdf
Coming Soon
State of the Knowledge on Pedestrian and Bicyclist Safety (awarded September 2017, 36-month effort)
Evaluating Enforcement of Bicycle Safety Laws (awarded September 2016, 48-month effort)
Law Enforcement Training on Bicycle and Pedestrian Safety
Effect of Electronic Device Use on Pedestrian Safety
• Naturalistic Observations (Phase 2)
• Crash Report Analysis (Phase 3)
Determining Ampaired Pedestrians Among DWI Offenders (final report anticipated release date: spring 2019)
Impact of Lowering Speed on Pedestrian and Bicyclist Safety (awarded September 2017, 60-month effort)
Safety in Numbers - Literature Review (final report anticipated release date: fall 2019)
New Research: Measuring Pedestrian Exposure Using Personal Electronic Devices (awarded September
2018, 60-month effort)
Community-Based Pedestrian and Bicycle Safety Assessment Tool (anticipated release date: fall 2019)
U.S. Department oflrcnsportatlon

National Highway Traffic saretv Administration
156
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 7
WHY AMERICAN TRUCKS ARE SO DEADLY

FOR PEDESTRIANS AND CYCLISTS
157
4/2!:i/2019 Why American Trudcs Are So Deadly for Pedestrians and Cydists- Streetsblog USA
~ -
OUR SITES STREETFILMS DONATE
STREETS BLOG
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Why American Trucks Are So Deadly for

Pedestrians and Cyclists
By Angie Schmitt Oct 31, 2016 • 9
arge trucks are a leading killer of cyclists and pedestrians in urban areas. While
London has recently decided to kick the most dangerous trucks out of the city, in the
U.S., truck safety regulations are much further behind.
Engineer Alex Epstein of the Volpe Center,

a research arm of U.S. DOT, spent five
years examining how truck design affects
bike and pedestrian safety. As a
government researcher, he's not
authorized to discuss federal regulations,
but his work is intended to guide policy.
We spoke with Epstein about what he's

Alex Epstein, left, a researcher with U.S. DOT's Volpe
learned and the potential implications. The Center, has been studying how side guards (the yellow lattice)
can prevent pedestrian and cyclist fatalities. Photo: Volpe
interview was lightly edited for length and
clarity.
So what have you been learning?
We've been looking at the impact on bicycle and pedestrian safety, particularly in urban
areas. The proportion of bicycle and pedestrian fatalities involving large trucks and the
proportion oftrucb on the road is not one-to-one.
Nationally it's more like 3 to 1 - three times as many bicyclists killed. So 11 percent of
bicyclist [fatalities are accounted for] by the 4 percent of vehicles on the road [that] are
trucks.
158 ..... and-cycristsl

https://uastreatsblog.orglZ>16/1G'31/why-arnericaMrucb-ar•so-deadfy-for-pedastri
m 1/9
4/2512019 Why American Trucks Are So Deadly for Pedestrians and Cyclists- Streetsblog USA
In cities, it's more disproportionate. In New York City, about 32 percent- about one out of
every three cyclists that are killed - are killed by a truck. And for pedestrians it's about on
in eight.
I
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
And you've been investigating some possible solutions?
Starting with some of the low hanging fruit, for example side guards as a mitigation.
Trucks by design have large blind spots, or really a set of blind spots. It means that the
visibility in a truck is not as good as it is in an automobile. And then the vehicle is so high off
the ground and has a large turning radius. When turning for example, they may be
particularly hazardous. When pedestrians are out they might not be visible. And when
collisions happen, they are deadly collisions.
There's a study, in San Francisco, when a Nearly half of bicyclists and more than
one-quarter of pedestrians killed by a
pedestrian was in a collision with a bus or large truck first impact the side of a truck.
truck, the chance of dying was eight times
greater than the chance when one is hit by
an automobile. And then in London, I
believe they suggested they were 78 times
more likely, but that was specifically for
trucks. That is not good news.
We also saw [that] about one in two

bicyclists killed [initially) hit the side of the
truck, which is where people on bikes will
fall under the trucks and be run over. We
just had, unfortunately, a number of those Vc!;ia
types of crashes in the Boston area this Image: Volpe Center
summer.
That's where side guards or side underride guards help, by keeping the person over the
wheel pass of the moving truck.
We actually published a voluntary side guard standard [PDF] to bring a consistent

specification to vendors or local areas that wish to use it. So that's on our website and I feel
like it's really raised the level of awareness about that particular technology. But that's the
last line of defense when a collision is already happening.
159
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a
2/9
4125/2019 W~ American T ruclcs Are So Deadly for Pedestrians and Cyclists- Streetsblog USA
There are many things upstream of that we're looking at for crash avoidance, everything
ranging from additional mirrors to increasingly sophisticated cameras and alert systems, t
redesigning the truck cab itself to the kind of direct vision standards London is nsideri
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
There's not very much out there that governs the visibility that a driver has. In the
European and U.S. context, truck cabs have not changed much in decades. They don't
provide a particularly good or complete field of view. While that's problematic in a highway
setting, it's especially problematic in an urban setting where other road users are closer and
there are far more turns.
I don't know if you've ever sat in a truck cab. I've sat in quite a few for my research and it's
surprising how much you cannot see. A 6-foot-tall man or woman can stand directly in front
of some of the larger trucks, particularly construction vehicles, and be fnvfsfble.
The federal government does regulate truck design just like they do with cars, right?
I can give you some broad brush strokes of what is and isn't regulated. In general, I can cite
a 2006 review by Dan Blower from the University ·of Michigan ~t did :a review and Found
there is no federal reqU:irement for direct vision. And generally there's one requirement for
mirrors, which is just a planar mirror. The reality is, most trucks out there have a lot more.
There are truck models that provide better vision than others, which is why London is trying
to differentiate them and give them a five-star rating. This becomes a metric on which fleet
operators can buy them. That's an issue that we need, to look at, and that's why we've been
looking at it. The EPA has fuel economy ratings for cars. There's not realiy a visibility rating
for trucks.
One way that the cities that are taking on truck safety are going about it is using their power
of procurement. And then that can become a metric for how they procure things.
What I heard is that Boston is the only city in the U.S. that's doing that - restricting
its contracts to companies with trucks that have side guards.
Boston has the side guard and crossover rninor ordinam.:e fo1 its (:QRtfa(:tors. Washington,
DC, is the first to take this on at the state level and in July passed a side gua1dlaw for aH
trucks registered [there J, that was called the Bicycle and Pedestrian Safety Amendment Act.
That's a fairly momentous move.
That means trucks can't drive into DC unless they have side guards and those sped~
~rmn?
160
II
https://usa.streatsblog.org/2016'1CY31/why-arnerican-trucb-ar~10-deadly-for-pedestrians-and-cyclilts/ '319
4/25/:i!>19 W'rty American Trucb Are So o.dly for Pedestrians and Cycilists- Stremblog USA
No. Similar to other state laws out there, similar to the New York State crossover mirror la~
that only applies to in-state trucks - in that case, in-state registered trucks that operate
inside New York City. Trucks registered in New Jersey are not subject to that. Trucks ~
1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
registered in DC or Maryland could still drive through and not be subjected to that. Other 1-
states like Oregon and Washington have crossover mirror laws as well. 1
1~j
How have safety devices like this become mainstream historically. What would be
the process for that?
The progressive players in the industry will adopt it first. They will say, "This will save lives.
My company saves liability from lawsuits." And [there are] other types of things that they
might be concerned with,like good citizenship. Those
.
progressive early adopters
,
then ,make :
it possible to standardize that through guidelines, policies, standards. Then there's someone
to work with.
That's what Transport for London did. They launched a freight operator recognition scheme
and then formalized it.
Filed Under: Bicycle Safety, Trucks
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Name
Jason • 2 )'ears ago

Since the truck in the drawing appears to be a garbage truck: quick Googling says that the weight
of an empty garbage truck is almost exactly eight times the weight of the average car. I know it
could just be coincidence but it was hard not to notice that it's the same multiplier as found in that
study for how much more likely you are to be killed by a truck than a car.
,.. .., • Reply • Share>
Fay Nissenbaum • 2 )'ears ago

When a long truck turns a comer, lt'.s like a bHlboard - a rectangle going around a curve. The long
separation between front and back wheels pushes the wall of it at the pedestrian or cyclist in a
strange manner - the back wheels do not follow the front wheel path we tend to pay attention to -
they cut the comer tighter, aiming at you. So when you're standing there judging the front of the big
beast, the back is the part you really want to perceive (The same mistake happens with new truck
and bus drivers, where they must learn the back wheels make a tighter arc (hence the phrase from
instructors to drivers, "drive from the back of the bus"). 11!1
Can cities require side-guards or must that come from the Fed? Iii
162
https://usa.streetsblog.org/201611IY31/why•american-trucks-ar• so•daadly-for-pedestrians-and-cydist:w' 5/9
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 8
SPEED LIMITS LEADING TO CHANGE
163
0 INDUSTRY UPDATE
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Speed Limits: Leading to Change

BY RANDY MCCOURT, P.E., PTOE (F), KAY FITZPATRICK, PH.D., P.E., PMP (F),
PETER KOONCE, P.E. (M), AND SUBASISH DAS, PH.D. (M)
n January 2019, the National Committee on Uniform Traffic Control Devices

(NCUTCD) voted to send a ballot item to the Federal Highway Administration (FHWA)
to revise language in the Manual on Uniform Traffic Control Devices (MUTCD)
regarding the setting of speed limits.1 In January 2018, the NCUTCD established a task
force to further understand the recommendations made by the National Transportation Safety
Board (NTSB), Reducing Speeding Related Crashes Involving Passenger Vehicles. 2•3 The task force
conducted a survey in the spring of 2018 of the profession to identify practices and attitudes
related to setting of speed limits, and 740 professionals completed the survey.
At the 2018 mid-year NCUTCD meeting, the task force met with the The appr<md ballot item was then forwarded to FHWA quickly,
NCUTCD Technical Committees and facilitated an open discussion following the January 2019 meeting, for hopeful incorporation in the
with the NCUTCD. The national committee provided direction upcoming update of the MUTCD.'
to refine language related to speed limit setting recommended in Setting of speed limits elicits some of the most passionate
the next edition of the MUTCD. The recommended changes made technical and emotional responses in our industry. The topic
by the NCUTCD addresses many of the NTSB recommendations of vehicle speeds and speed limits is one of the most frequently
and issued a ballot item for comment to the seventeen sponsors of researched topics in our industry. More than two dozen detailed,
the NCUTCD, including the Institute of Transportation Engineers relevant research efforts were reviewed by the task force. To
(ITE). The task force responded to nearly 100 comments from the understand the context of this proposal, the history of speed limits
sponsors and a revised ballot item was approved by the Regulatory in the MUTCD, NTSB recommendations, NCUTCD task force
and Warning Sign Technical Committee to be sent to the NCUTCD. efforts, and the next steps are summarized.
38 April 2019 lie 111,111
164
History the setting of speed limits by allowing traffic engineers to system-
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
The language in the MUTCD has evolved over time related to atically incorporate crash statistics and other factors in addition to
setting of speed limits. The initial discussion on this topic was in the 85th percentile speed, and to validate their engineering studies.
1948 and the MUTCD indicated: The Safe System approach to setting speed limits in urban areas was
noted as an improvement over conventional approaches because it
The limit that is displayed on the sign shall be the prima facie considers the vulnerability of all road users.
or absolute speed limit established by law, or a prima fade or
absolute speed limit established after appropriate engineering NCUTCO Task force
and traffic i~igation acco,ding to law. In addition to the NCUTCD task force survey, the Texas A&M
Transportation Institute (ITI) was conducting the National
A key element of setting speed limits (i.e., when non-statutory, Cooperative Highway Research Program (NCHRP) project 17-76
requires a study) is still present in the current MUTCD paragraph I. (Guidance for the Setting ofSpeed Limits) which is scheduled to
The 1961 MUTCD language was similar, but in 1971 the factors be complete in the fall of 2019. The task force survey data were
of a traffic investigation were added to provide practitioners provided to the TTI team to assist with the investigation. AAA
with guidance. The list of factors included characteristics, speed also was conducting a similar survey of speed limits and collabo-
distribution (both 85th percentile speed and pace speed), roadside ration with AAA was undertaken. The background findings of the
development, geometry, parking/pedestrian activity, and accident NCUTCD task force survey included the following:
experience (the first appearance of the Mlist of factor5" that exists • While consultants were the most represented single group in
today in section 2B.13). This language carried forward to the 1978 the survey (approximately 27 percent), public agencies were the
and 1988 manuals. In the 2000 manual the list of factors was ~ overall rttponding group (state agency/OOT (approx-
converted to an option and guidance was added that speed limits imately 18 percent), smaller cities (approximately 17 percent),
should be rounded up from the 85th percentile. This was the first county/regional agency (approximately 16 percent) and larger
time pace speed was separated from 85th percentile speed when cities (approximately 9 percent).
discussing speed distributions. In the 2003 MUTCD, guidance • Survey respondents averaged 20 years of professional experience,
was added to re-evaluate non-statutory speeds every five years and compared to a typical ITE member who has about 18 years of
simply stated the rounding (not just up) requirement. The five-year experience (nearly 15,000 collective years of experience).
study frequency was replaced in 2009 to re-evaluate roadways that • Participants had a wide range of experience with speed limit
have undergone significant changes. The 2009 manual made several studies, somewhat equally spread over the five survey categories
additions which separated the "list of factors" from the standard of of 0, 1-5, 6-20, 21-50, 50+ years of experience.
doing engineering studies. • More than 85 percent of the respondents have regularly (just
less than 60 percent) or occasionally (about 25 percent) used the
NTSBReport MUTCD.
In July 2017, the NTSB issued its report on speed related crash • A majority of respondents depend upon the MUTCD or state/
reduction. It included numerous recommendations. The NTSB local guides/requirements in setting a speed zone.
focused on the following five safety issues pertaining to the effective • Few respondents have used USLIMITS2 (16 percent)-this is
application of proven and emerging countermeasures for speeding: consistent with other recent surveys conducted by the AASHTO
1) speed limits, 2) data-driven approaches for speed enforcement, 3) Committee on Traffic Engineering that indicates limited state
automated speed enforc.ement, 4) intelligent spud adaptation, and DOT use of USLIMJTS2. 7
5) national leadership. It included four specific recommendations
directed to FHWA and the MUTCD.5 The survey of the top five factors viewed as most important
The basis for the NTSB recommendations were findings that from all participants were context-location (57 percent), crash
there is not strong evidence that, within a given traffic 6ow, the history (46 percent), speed of vehicles (46 percent), pedestrian
85th percentile speed equates to the speed with the lowest crash activity (41 percent), and geometrics of the road (33 percent).
involvement rate on all road types. 6 They stated that the unintended While all analysts consider speed. crashes, and context important
consequences of the reliance on using the 85th percentile speed factors, the survey exposed a changing trend in importance of
fur changing speed limits in speed zones include higher operating certain criteria. The percent of the respondents selecting each
. speeds and new, higher 85th percentile speeds in the speed zones, criteria was compared by experience levd. When breaking out
and an increase in operating speeds outside the speed zones. Expert the responses to the five most important factors for those who
systems such as USLIMITS2 were noted as being able to improve have less than 10 years of experience versus those who have more
WWW.Ill.HI April 2019 J9
165
than 20 years of experience, a trend becomes apparent. Younger
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
professionals are placing greater importance on context and

modes (very likely urban related) and more experienced profes-
sionals are placing greater importance on access, geometrics,
ci::-
and speed. While this result has been shrugged off by some as a C) .>
-
safety._ •-
"they did not know better," it is worthy of further discussion as all
analysts consider context important and emerging professionals
cr, o
appear to be diving into how to characterize this factor better than roadway~ u~ers
context
in the past.
Table I. Changes in speed setting criteria importance by experience level
set
Criteria that•• IIION
lnlpwtaalfar.._wlllt 10
yeanefmqmfar.eetteN
-- -
....................
-· ··-
.. . . 20,-Sflf-,erilftal
,,..,..,
more
~
land
percentile ~~Srred
speeds g,
V •
c:amparadto . . . . . . . 20 .c,. . . . . . . . . . . . . . 0
- - - .m
Bicycle Activity Speed of Vehicle
Pedestrian Activity Statutory Reqoirements
Policy Geometrics (sight distance) Figure I. Word cloud of responses to question asking how would
Context - Location Percent Vehicles over PSL/% Pace professionals set speed limits, ifgiven the choice.
Contl!xt - Laod Use Access Management
insights into understanding if or how speed distribution may
No~ Rndings only in dude portidponn rhoc hod done at leosr one speed study
have changed over time (speed creep).
Related to setting speed limits and rounding, the most frequent • To clarify the use of the 85th percentile speed, limit the
response was to round to the nearest 5 miles per hour (mph) (8 specificity of setting speed zones within 5 mph (8 km/hr) of the
kilometers/hour [km/hr}) of the 85th percentile; but when given 85th percentile for fneways, expressways, and rural highways.
the option to choose how they "would• do it they offered nearly 350 • The industry use and knowledge ofUSLIMITS2 is very limited
observations and context was the most frequent word used in the (it was originally developed in 2006). Before prescriptively
comments. A word cloud was developed based on the number of requiring it as a methodology in MUTCD for setting speed
word frequencies and is shown in Figure 1. The size of a word is an zones, more information is needed about why analysts do not
indicator of word frequencies present in the text body of responses. use it currently. A survey participant noted that the assessment
It was dear from the survey that while there may be occurrences should be more transparent to users (less of a black box). In
of people narrowing their speed zone assessment to only the 85th addition, requiring the use of a specific process is not likely
percentile, this is rarely done. Analysts look at many factors. Even appropriate for the MUTCD and rather should be part of
with the variations between more experienced and less experienced national guidance documcnt(s) for states/locals to utilize in
analysts or having done studies to having not done studies, speed establishing their policies.
distribution was nearly always viewed as a key factor. The task • Setting of reasonable speed zones requires consideration of
force made the following findings in its recommendation to the many factors that are not well defined in the MUTCD. These
NCUTCD Council: factors are best defined as part of national guidance/research
• Use of speed distribution in setting of speed zones is important documents and do not need to be defined in the MUTCD as
but is only one of the factors in setting speed zones. they can involve state/local interpretation.
• Reinforce that the "other• factors should be considered in • The majority of task force members were not supportive of the
conducting speed zone studies and a change from option (may) elimination of studies in setting of non-statutory speed zones
to guidance (should) be made (returning it to its historic status). givm the safety, enforcement, and legal consequences.
• The inclusion of bicycle activity as one of the "'factors" both in • As the NCHRP 17-76 research progresses, consideration of
terms of road context and road users. target speeds (rdkcting on survey findings in Table 2 and
• Clarify "factorsD to include lane widths, medians, driveways, NCHRP 855 Table 2) should be considered further, but not be
land use, and past study data. Past studies provide v.uuable part of MUTCD.
4t April 2019 Ill IHr• al

166
Related to the concept of Safe Systems, the changes to consider B. Reported crash experience for at least a 12-month period relative
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
ma.ximiz.ing pace speed (a 10 mph (16 km/hr) range where the to similar roadways.
greatest percentage of vehicles can be found in a speed distribution), C. Road characteristics (such as lane widths, curb/shoulder
road context, and road users are all aimed to better address the condition, grade, alignment, median type, sight distance).
needs of vulnerable users in urban areas. Pace particularly is a D. Road context (such as roadside development and environment
statistic that can be utilized more effectively in setting speed limits. including number of driveways, land use, functional classifica-
Considering context and having less speed variation contributes to tion, parking practices, presence of sidewalks/bicycle facilities).
safer roadways. 8 Studies have outlined that it is not speed but the E. Road users (such as pedestrian activity, bicycle activity).
greater variation in speed that contributes to crashes-particularly
excessive speed. Using the naturalistic driving study data, the Iowa Olb When a speed limit within a speed zone is posted on freeways,
State University study showed that the risk of a crash or near-crash expressways, or rural highways, it should maximize the
increased significantly with increases in the standard deviation percentage of vehicles in the pace and should be within 5 mph of
of speeds over the course of each event. Selecting speed limits to the 85th percentile speed offree-flowing vehicles
maximize the pace can contribute to fewer crashes and the negative
consequences associates with such crashes. The Steps Ahead
It should be noted that the NCHRP Report 855 also highlighted Completion ofNCHRP 17-76 will provide greater guidance for
that "bicycle separation is highly contingent on the difference local and state agencies who develop policies related to setting of
between bicycle speed and motorized traffic speed.,. Essentially, as speed limits. This will include more informatioo on definitions and
speeds go up, the separation should also increase. Intersections are applications. The NCUTCD survey clearly established that most
of particular concern to pedestrians and cyclists alike. Provision of professionals rely on local and state policies in combination with
appropriate crossing treatments become critical where speed is high. the MUTCD in conducting analysis of speed zones. The policies are
Based upon these findings, the following recommended text was the place where greater detail can be placed regarding the definition
forwarded to FHWA as part of the NCUTCD recommendation 10 and use of factors in setting of speed limits, including the use of
regarding possible changes to the MUTCD. While other editorial USLIMITS2 as a validation tool
changes were also made, these are the key sections that relate to the Exposed in this effort to update the setting of speed limits was
NTSB report. the need to consider culture changes for communities wishing to
eliminate serious injuries and fatalities associated with motor vehicle
Standard: crashes. The task force highlighted the need for expanded collabo-
01 Speed :r.ones (other than statutory spud limiu) shall 8lliy' be ration between engineering. enforcement, and judicial professionals
established on the basis of an engineering study that has been in the application of speed limits to achieving the goal of reducing
performed in accordance with traffic engineering practices. excessive speeding. crashes, and fatalities. The Governors Highway
Safety Association recently released a report11 that places the target
Guidance: on the need to address excessive speeding. They found that:
Ola Factorsthat should be considered when establishing or reevaluat- • Progress on the issue of excessive speed has been limited at best.
ing speed limits within speed zones are the following: • Efforts to combat speeding face political roadblocks.
A. Speed distribution of free-flowing vehicles (such as current 85th • Whm it comes to speeding, drivers have a minimal perception
percentile, the pace, review of past speed studies). of risk.
Table 2. NCHRP Report 855' Suggested Ta,xet Speed for Context/Roadway
c.tal
- -- - - -
lloldwaJ
- -
- Rural RuralTown Suburban Urban Urban Core
Freeways Not addressed in 8S5 since •designs are based on federally developed standards with Ottle flexibility.' Assumed to be high.
Principal Arterial High Low / Med Med/High Low l: Med Low
Minor Arterial High Low/Med Med Low/Med Low
Collector Med Low Med Low Low
Local Med low Low Low Low
Suggested target speeds: Low (<30 mph), Med (30 to 45 mph), high t> 45 mph)
WWW.Ill.art April 2019 41
167
This is where the Institute of Transportation Engineers is wdl enforcement, emergency services, and road users who share the
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
positioned to make a difference. By working collaboratively with desire of getting home alive and safe. Let's work together to Shape
enforcement professionals to define how to set speeds that best our Communities. itej
address the needs of communities, we can build a culture that
reinforces safe speeds and makes excessive speed and its thousands References
of fatalities unacceptable. Working with the judicial system, we 1. NCUTCD Item RW18B-RW-03 Speed Limit Procedures, https://ncutcd.
can develop approaches and systems that support enforcement org/wp-content/uploads/meetings/2019NAttachNo 12.188-RW--03.
personnel in this pursuit rather than waste their energy, time, and SpeedlimitProcdedures.Approved.pdf.
resources by not adjudicating excessive speeding to the greatest 2. Reducing Speeding Related Crashes Involving Passenger Vehicles, National
extent of the law. We can tackle distracted driving and driving under Transportation Safety Board, DOT, NTSB/SS-17 /01, July 25, 2017.
the influence of alcohol or drugs together with speed not in silos. 3. Federal Highway Administration (2009) Manual on Uniform Traffic Control
We can advance development of enforcement methods that do not Devices for Streets and Highways, http://mutcd.fhwa.dot.gov.
result in the perceptions of entrapment or the beliefs of"agency 4. Federal Highway Administration, Federal Highway Administration Plans
undue enrichment." We can use "big data" to our advantage in better New Edition of National Traffic Conrrol Manual to Address Innovation, Get
understanding the rdationships of speed management, crashes, and Ready for Automated Vehicles, October 5, 2018 [Accessed March 6, 2019)
safety. We can openly share those data and knowledge collaboratively https://www.fhwa.dot.gov/pressroom/lhwa 1823.cfm /.
amongst our industries. We can work through these barriers together 5. NTSB. Ibid, page 57.
in building a culture that values both the safety of our communities 6. NTSB. Ibid, page 54.
and the rational mobility of travelers and goods movement. 7. 2017 Survey: USLIMITS2, Committee on Traffic Engineering, AASHTO,
There are partners all around us in education, public Aug'!st 2017, httpsJ/tiaffic.transportation.org/surveys/.
outreach, medical professionals, AAA, MADD, truckers, AARP, 8. 7he Interrelationships between Speed limits, Geometry and Driver Behavior,
Center for Transportation Education and Research, Iowa State University,
November 2018, page 78.
9. An Expanded Funcrional Classification System for Highways and Streets, NCHRP
Safe Speeds for City Streets: 855, TRB, 2018, interpretation of speed to functional classifications system.
A Practitioner's Guide to 10. NOTE: recommendations to FHWA do not represent changes to the
MVTCO. They wiff consider this recommendation as they advance the
Speed Limit Setting update to the MUTCD in the next year.
l 1. Speeding Away from Zero: Rethinking a Forgotten Safety Challenge,
Guidance from the Nationaf Association Governors Highway Safety Association, January 2019.
of City Transportation Officials (NACTO),
released this momt.i. gives practitioners a
detailed, context-sensitive method to set
safe speed limits on urban streets. Using
me Safe S)'!,tems approach, the guidance
provides a consistent. rational, scalable
approach to urban speed limit setting. from
ll.J
I
F-.
I ·
Randy Mccourt, P.E., PTOE (F) has been actively
involved in transportation engineering and planning as
a Principal uJ DKS Associatesfor 40 years out of
Portland, OR, USA. He is a graduate of Oregon State
citywide strategies to corridor-by-corridor methods based on
University (civil engineering) and the University of
easy-to-study street characteristics. California, Berkeley (transportation engineering). Randy has been
engaged in the Institute of Transportation Engineers his entire career
The National Traffic Safety Board (NTSB) has recommended an having served at all levels and currently is the International Vice
overhaul of how speed is managed on U.S. streets, induding President. Randy has authored numerous ITE publications and
the .way that speed limits are set. Answering this.call, NACTO's
papers including Parking Generation, as well as chapters of the
new guidance, based on best practices from a wide diversity
of municipalities across North Amerfca, gives pcactltfoners Traffic Engineering and Traffic Control Devices handbooks. He has
the specific methods-at the level of an entire city or a single been involved with the National Committee on Uniform Traffic
street- needed to set safe speed limits on streets. Control Devices since 2007 and has chaired and participated in
several task force activities in several areas including dynamic
Visit nacto.org/safuspeeds for more. message signs, LED, BRT, parking signs, site roadways open to public
tTave~ and most recently the speed limit task force.
42 April 2019 lie 111,nal

168
Portland State University teaching graduate level courses in
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
.............. ••••-m••••••-•-••••••••-••• .. ••• .. •-.,•••••.. •-•-• .. - --•• ..••••••••••- •..• - - -- -
Kay Fitzpatrick, Ph.D., P.E., PMP {F) has been transportation engineering. He is a member of the Bicycle Technical
honored with the Burton W. Marsh Award for Committee of the National Committee on Uniform Traffic Control
Distinguished Service to ITE. She was the president of Devices appointed by the Association of Pedestrian and Bicycle
the 1TE Brazos Valley Section and the Local Professionals.
Arrangement Chair for the 2015 Spring TexITE
Meeting. Formally, she was a member of the executive committee Subasish Das, Ph.D. (M) is an Associate
and then chair of the ITE Traffic Engineering Council. She has Transportation Researcher with Texas Ao-M
written chapters in the ITE Traffic Engineering Handbook and the Transportation Institute in College Station, TX, USA.
Urban Street Geometric Design Handbook and was one of the His major areas of expertise include statistical analysis
assistant editors for the 2000 edition of the ITE Traffic Control and machine learning with an emphasis in transporta-
Devices Handbook. She is the co-author of several lTE Briefing tion safety and operations, spatial analysis with web GIS tools,
Sheets, ITE Compendium articles, and ITE Journal papers. interactive data visunlization, and deep learning.for CV/AV
technologies. Subasish completed his M.S. and Ph.D. in civil
Peter Koonce, P.E. {M) manages the City of Portland engineeringfrom the University of Louisiana at Lafayette. He is an
Bureau of Transportation's signals, street lighting, and Eno Fellow.
ITS Division and is responsible for the cwersight of an
annual budget in excess of $20 million and 53
professionals. He has served as an adjunct professor at
••
, '
·1i '; what
~~,
ma~e\
a smart city.
~ ;J
Yvrk
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!
. \ ll,
Live"'-allows use
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rs to
.... ·r intersections
a.:' view activ, . lly collecting and
I '_ by automatic a. 16 bicvc:\e and
.,. '& a nalyzing veh1c e. _
·.Ti i •
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I
lpedestrian data.
I
iteris.com,,vant agelTOI
WWW.Ill.Ir • April 2019 43
169
)
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 9
SPEED LIMIT REDUCTIONS
170
4/27/2017 lbOT agrees to e,wand 25 mph $Peed limit zone in downtown J Kane County Chronicle
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
PARAMOUNT
Ttfr A Tlf
IDOT agrees to expand 25 mph speed limit zone in

downtown
By KANE COUNTY CHRONICLE ·. editorialOkcchronicle.com
Dec. 13, 2016
ST. CHARLES - The Illinois Department of Transportation has agreed to lower the speed
limit on Main Street/Route 64 in St. Charles to 25 mph from Seventh Street and Seventh
Avenue.
This expands the current 25 mph zone from Fourth Street and Fourth Avenue. IDOT will
install new speed limit signs, according to a news release.
KANE COUNTY CHRONICLE

171
http:/Jwww.ka:hronide.com/2016/12/09fldot-agrees-to-expand-25-mph-speed~mit-zone-irHfowntown/a8fl43th/ 1/4
4/27/2017 25 MPH Speed Limit Zone Expanded on Main Street INews f City of St Chades, ll
~ CITYOF
E:I ST. CHARLES MENU
~ '>'- ILI.INOIS • SINCE IBJ4 "$>

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
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ABOUT
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SERVICES & SAFETY
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FOR BUSINESS
25 MPH Speed Limit Zone Expanded on Main Street

»
Lower Speed Limit Stretches from 7th Avenue to 7th Street
At the request of the St. Charles Police Department, the Illinois Department of Transportatio
(!DOT) has reduced the speed limit on Main StreeUIL Rt. 64 to 25 MPH between 7th Street &
7th Avenue. This expands the previous 25 MPH zone between 4th Street & 4th Avenue. IDOT •
has installed new speed limit signs alerting drivers to this new speed zone.
Police requested the speed limit reduction in an effort to calm traffic as it travels through the
heart of our downtown, enhancing safety of both pedestrians and motorists. The City
encourages all motorists to Slow Down, Downtown.
"I am glad staff was able to work with IDOT to get thr tower speed zone expanded on Main
Street," said Mayor Ray Rogina. "It's important for pepple to feel safe as they walk or drive
through our city and that traffic conditions are condvcive to visiting our businesses. Our
enforcement strategy and changing the mindset of ~rivers will be the keys to success on
slowing speed on this and aH City streets."
Because Main St.Ill Rt. 64 is a state highway, it was necessary for IOOT to conduct an
investigation into the recommendation for the speed limit reduction. "IDOT's results mirrored
172
htlps://www.stcharlesil.gov/news/2017/03/01/25-mph-speed~t-zone-expanded-fflain-slteet 1/2
4/27/2017 25 MPH Speed Limit Zone Expanded on Main Street I News I City of St Charles, IL
those of a 2016 traffic study conducted by the St. Charles Police Department which
confirmed vehicles were consistently moving faster through our downtown than the posted
speed limit," said Commander of the St. Charles Police Department Traffic Division Jerry
Gatlin. "By expanding the 25 MPH speed zone, it wiH ensure the safety of pedestrians and
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
motorists downtown."
For more information, contact Commander Gatlin at 630.377.4435.
© 2017-City of St. Charles

2 E. Main Street
St. Charles, IL 60174
630.377.4400
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Woodstock Route 14 Construction Nearly Done; New Speed Limit is 45 MPH - The Woo… Page 1 of 2
Woodstock Route 14 Construction Nearly Done;

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
New Speed Limit is 45 MPH
Motorists traveling along Highway 14 may have noticed lane changes last week, a sign
the twoyearlong road construction project is nearing completion.
One of Highway 14’s newly constructed eastbound lanes was opened to traffic, officially
separating motorists who have been navigating cones, barricades and lane shifts since
the fall of 2014.
“The project is on schedule to be completed this fall,” said Gianna Urgo, public infor
mation officer for the Illinois Department of Transportation.
The $48 million road improvement project led by IDOT starts at Lake Avenue in Wood
stock and continues south to Crystal Lake. The original twolane highway has been trans
formed into two, twolane roads separated by a median.
The new highway should provide less traffic congestion and backups at traffic light sig
nals. But don’t count on driving as fast on the road. IDOT has decreased the speed limit
for Highway 14 from 50 to 45 mph, Urgo said.
174
https://www.thewoodstockindependent.com/2016/08/woodstock-route-14-construction-near… 5/2/2019
Woodstock Route 14 Construction Nearly Done; New Speed Limit is 45 MPH - The Woo… Page 2 of 2
“The new fourlane road with curbing warrants the speed limit to be changed to 45
mph,” Urgo said.
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
According to IDOT, the Highway 14 road construction project was necessary as the “old
pavement needed to be replaced and upgraded to accommodate current traffic
demands.”
The project involved building two, 12footwide lanes in each direction, separated by a
22footwide raised, landscaped median. The drainage system and signs were completely
replaced, as well. In Crystal Lake, the road was widened and resurfaced from Crystal
Lake Avenue north to Highway 176, according to IDOT.
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The project also includes traffic signal improvements where Highway 14 intersects West
Lake Shore Drive in Woodstock; Lucas Road near McHenry County College; Ridgefield
Road South; Highway 176; and Woodstock Street and Crystal Lake Avenue in Crystal
Lake. A new traffic light was installed at the Highway 14 and Doty Road intersection near
Centegra HospitalWoodstock, according to IDOT.
The project offers bicyclists a new, safe route as well. Once completed, a 10footwide
multiuse path will run from West Lake Shore Drive in Woodstock south to Crystal Lake.
The path will veer away from the Highway 14 corridor just south of McHenry County
College. The path is separated from the highway and runs along the north side of the
road.
The project was coordinated with the city of Woodstock, the city of Crystal Lake, the
McHenry County Department of Transportation, McHenry County Conservation District
and MCC.
175
https://www.thewoodstockindependent.com/2016/08/woodstock-route-14-construction-near… 5/2/2019
"'!_,-') /.
-.._..,
.. !-e1
--- '-
-
.....
Illinois of lransportation
Division of Highways/Region 1 1 District 1
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
201 West Center CoUlt/Schaumbc&rt,.Mfmois $0196-1096
ST 3.3 (L) IL 43
March 3, 2005
Mr. Barry A. Bolek

Assistant Superintendent for Finance
Township High School District 113
1040 Park Avenue West
Highland Parle:. IT., 62764
Dear Mr. Bolek:
This is a follow-up 10 our letter of January 6. 2005 regarding the postr:d speed
limit on IL 43 in the vicinity of the Deerfield Higb School entmnces.
We have recently completed a speed sluJy on IL 43 bctw,;cn North Avenue und

IL 22. The study results indicate that tJ1e 45 mph speed zone is proper with a
47.6mph adjusted prevailing speed. We will. however, in the interest of safety,
extend the existing 35 mph zone north to include hoth school entrances. Signing
revisions have been ordered and will be done as soon as our work schedule wiU
allow
1J you have any quc~tions or need additional infom1ation, please contact Rodger
Neubert, Data Collection Technician, at (847) 705-4091 .
Very truly yours,
U1 ane M O'Keefe, P.E.

Region One Engineer
176
STATE OF ILLINOIS
ROUTE: ILLINOIS 68 (DUNDEE ROAD) ZONE: LENGTH: 0.85

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FROM: 1- 94 [EDENS EXPWAY (East Ramps)] TO: West of BALLANTRAE DRIVE

M.S. # 0.16 M.S. # 24.98
.....................................................................................................................................................................................
CITY: NORTHBROOK lWNSHIP:
COUNTY: COOK NORTHFIELD
.................
CHECKPOINT 85th % PACE
********
RATE
........................ ................. CHECKPOINT
........ ......... ...............
85th % PACE RATE
1 CP # 1A (EB) 46.0 45.0 53.6 6 0.0 0.0 0.0

2 CP# 18 (WB) 43.0 43.0 32.5 'i 7 0.0 0.0 0.0
3 CP # 2A (EB) 48.0 46.0 55.4 8 0.0 0.0 0.0
4 CP# 28 (WB) 45.0 43.0 42.3
5 ':) 9 0.0 0.0 0.0
5 0.0 0.0 0.0 10 0.0 0.0 0.0
········••tt••·....·············•tt..........................................................................................................................................
85th % AVG.: 45.5

ZONE STUDIED: 40 MPH
UPPER LIMIT: VIOLATION RATE:
44.3 46.0 %
NO. OF CARS IN VIOLATION: 92
DIRECTION: WEST 45 MPH LGTH: 1.10
PREVAILING SPEED: 44.9 DIRECTION: EAST 30 MPH LGTH: 0.30
......................................................................................................................................................,.............................
MAJOR STREETS(1 Ox) 2 = 20 PEDESTRIAN VOLUME 10+/HR: 0

MINOR STREETS(5x) 3 = 15 PARKING PERMITTED: 0 > Y=1
LG BUS DRIVES(1 Ox) 0 = 0 TOTAL NO. OF ACCIDENTS: 102 N =0
SM BUS DRIVES(Sx) 7 = 35 NO. QF INJURY ACCIDENTS: 18
RES DRIVES(1 x) 8 = 8 NO. OF FATAL ACCIDENTS: 0
ACCESS CONFLICT NUMBER/ MILE= 91.8 SEVERITY RATE: 0.18 'V,
A.D.T.: 37800
ACC FACTOR 870 378: 2.30
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,,,,, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IHr . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PART VI SPEED ADJUSTMENTS PART VII REVISED SPEED LIMIT
ACC. CONFLICT ADJ. 10 %** RECOMMENDED SPEED LIMIT: 40 MPH

ACCIDENT ADJUST 0%
(max. 10%) DATE: NOVEMBER 17 , 2000
ADJ EXCEEDS 10 % USE 10 %* **Do You Wish To Apply Access Conflict Adjustment? y =1
TOT. ADJ(max. 20%) 10 % N=0
44.9 X 10 % = 4.5 M.P.H.
PREVAILING SPEED ADJUSTMENT (max. 9 mph) APPROVED BY: _ _ _ _ _ _ _ _ _ __
ADJUSTED PREVAILING SPEED: 40.4 M.P.H. DATE:_ _ _ _ _ _ _ _ _ _ _ _ __
PERTINENT COMMENTS: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
177
STATE OF !LLINO!S
ROUTE: ILUNOIS 68 (DUNDEE ROAD) ZONE: LENGTH: 0 .85

FILED DATE: 5/6/2019 12:00 AM 2019CH05641
FROM: 1- 94 [EDENS EXPWAY (East Ramps)} TO: West of BALLANTRAE DRIVE

M.S. # 0.16 M.S. # 24.98
............................................................................................................................................................................................
CITY: NORTHBROOK TWNSHIP: NORTHFIELD COUNTY. COOK
..................
CHECKPOINT
........ ......................... ..................
85th % PACE RATE CHECKPOINT
......... ...........................
85th % PACE RATE
1 CP # 1A (EB) 46.0 45.0 53.6 6 0.0 0.0 0.0

2 CP # 18 (WB) 43.0 43.0 32.5 7 0.0 0.0 00
3 CP # 2A (EB) 48.0 46.0 55.4 8 0.0 0.0 00
4 CP # 28 (WB) 45.0 43.0 42.3 9 0.0 0.0 0.0
,. .................................... ,......................................... , ....

5 0.0 0.0 0.0 10 0.0 0.0 0.0
.......................................................................................................................
85th % AVG. : 45.5 ZONE STUDIED: 40 MPH

UPPER LIMIT: 44.3 VIOLATION RATE 46.0 %
NO. OF CARS IN VIOLATION: 92
DIRECTION: WEST 45 MPH LGTH: 110
...................................................................................................................................................................... ..,.
PREVAILING SPEED: 44.9 DIRECTION: EAST 30 MPH LGTH: 0.30
_

MINOR STREETS(5x) 3 = 15 PARKING PERMITTED: 0 > Y=1
LG BUS DRIVES(10x) 0 = 0 TOTAL NO. OF ACCIDENTS: 102 N=0
SM BUS DRIVES(5x) 7 = 35 NO. OF INJURY ACCIDENTS: 18
RES DRIVES(1x) 8 = 8 NO. OF FATAL ACCIDENTS : 0
ACCESS CONFLICT NUMBER / MILE= 91.8 SEVERITY RATE: 0.18
A.O.T.: 37800
ACC FACTOR
"···;,;..--;.:-·---;;;.;~:;;;;;_;;;;;;·""-";;:;·~.~w...........;;;:;~-;;;;;;:;~;··-..........
ACC. CONFLICT ADJ. 10 %** RECOMMENDED SPEED LIMIT: 35 MPH
STATE AVERAGE RATE:
870 I 378 :
378
2.30
~
z~·t·
:I--
t,
PEDESTRIAN ADJUST 0 % ANTICIPATED VIOLATION RATE: 79.5 %

ACCIDENT ADJUST 10 %
PARKING ADJUST 0 % RECOMMENDED BY: MICHAEL STRAUSS-HODER
HI ACC LOC ADJ. 0 % ORGANIZATION: BUREAU OF TRAFFIC
(max. 10%) DATE: NOVEMBER 17 , 2000
•1F ACC ADJ + HI ACC LOC
ADJ EXCEEDS 10 % USE 10 %- .. Do You Wish To Apply Access Conflict Adjustment? y =1
TOT. ADJ(max. 20%) 20 % N=O
44.9 X 20 % .. 9.0 M.P.H.
ADJUSTED PREVAILING SPEED: 35.9 M.P.H. DATE:_ _ __,_,,'-L....'1<.,<-"-'--------
PERTINENT COMMENTS: -- - - - - - - - - - - - - - - - - - - - - - - - - - - -
178
201 WestCenterCourt/Schaumburg, Illinois 60196-1096
1:,
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
I
ST. 3.3 (C) IL 68 (Dundee Ave.)
January 23, 2001

,-
Chief of Police
1401 Landwehr Road ! - . ---
!5
c;,<. ~!-i?.:f:_ - .~ ~
r-=~
As part of a periodic review program, a traffic and engineering speed stu<fy: was:
conducted on IL 68 (Dundee Ave.) from the J-94 east ramp Jct. to w/o .-the-
Northshore R. R. overpass in Northbrook to determine if any revision in the
posted limit is warranted.
The study results indicate the present 40 mph speed limit should be lowered to
35 mph. Signing revisions have been ordered, and will be done as soon as our
work schedule will allow.
The anticipated violation rate in the new 35 mph zone is 80 %. This information
is being provided to assist you in your program to provide selective
enforcernent.
We are enclosing copies of the speed data sheets for your consideration.
If you have questions or need additional information, please contact Lisa

Heaven-Baum, Traffic Studies Engineer, at (847) 705-4135.
Very truly yours,
John P. Kos, P.E.

District Engineer
By
John A. St: hw.irz, I1. E.
bee: J. Schwarz
L. Heaven-Baum
R. Neubert ~ "..-
S:\Gcn\\VP\Studics\pJO IO 123bST.docl'"'
179
lDOT Division Of Hi!!hwavs
nic:tri.-t Onn fnit I*
Dist. En2ineer ~ A
Illinois Department of Transpo ENG. Proj. Imp.

Construction
Local Roads
Materials
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
EEO
ST 3.3 (C) IL 68 (Dundee Ave) ENG. Pro2. Dev.
Desi2n
Land Acq.
February 6, 2001
Pro2rammin2
Public Info.
The Honorable Kathleen Parker ENG. Oper. 1'7L. 17 I
Illinois State Senator Elect. Oper:
Twenty-ninth Legislative District Maintenance I r..
191 Waukegan Road ~ Trafric I 'f J/i I
Suite 204 Administration
To:
Northfield, IL 60093 To:
* I = Information
Dear Senator Parker: 7 A= Action
This is a follow-up to our interim letter of September 15, 2000 regardin

on IL 68 (Dundee Ave.) west of the Edens Expressway.
A traffic and engineering speed study was recently conducted on IL 68 (Dundee Ave.)
from the 1-94 east ramp junction to west of the Northshore R. R. overpass in
Northbrook. The results indicate that the present 40 mph speed limit should be 35 mph.
Signing revisions have been ordered, and will be done as soon as our work schedule
will allow.
We have requested the Northbrook Police Department to increase their selective

enforcement in this new zone to ensure that the new limit is observed.
If you have any questions or need additional infonnation, please contact me or John
Schwarz, Traffic Programs Engineer, at (847) 705-4158.
Very truly yours,
John P. Kos, P.E.

District Engineer
bee: James C. Slifer

Matt Davidson
John P. Kos
Roy Fonda
John Schwarz
Lisa Heaven-Baum
Prepared By: Rodger Neubert, ext.4472
S:\Gen\ WP\Studics\prO I 0206.doc
180
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
)
Plaintiff, )
)
v. ) No. ____CH_____
)
)
Defendant. )

EXHIBIT 10
ILLINOIS STRATEGIC HIGHWAY SAFETY

PLAN 2017 – OBJECTIVES AND STRATEGIES
TO ADDRESS PEDESTRIAN CRASHES
181
TABLE PD-03 Objectives and Strategies to Address Pedestrian Crashes in Illinois
Implementation
Objectives (What) Strategies (How)
Objectives
Area(s)
1. Reduce vehicle 1.1 Implement more lane narrowing and road diet measures. Engineering
speed
and Strategies
1.2 Install traffic calming measures along road sections and at intersections. Engineering
FILED DATE: 5/6/2019 12:00 AM 2019CH05641
1.3 Increase enforcement for speeding and aggressive driving. Enforcement
1.4 Consider opportunities to reduce speeds through automated enforcement. Enforcement
2. Reduce pedestrian 2.1 Provide sidewalks/walkways with curb ramps. Engineering

exposure to
Illinois continues to strive to vehicular traffic 2.2 Install or upgrade traffic and pedestrian signals such as pedestrian countdown
Engineering
timers, pedestrian scramble and pedestrian detectors.
enhance pedestrian safety.
2.3 Construct pedestrian corner and median refuge islands. Engineering
Table PD-03 identifies some key 2.4 Evaluate and consider opportunities for access management or diverting
vehicular traffic to nearby routes to avoid high pedestrian travel areas. Engineering
objectives and potential strategies
2.5 Provide grade separated facilities where appropriate. Engineering
to address the contributing factors
2.6 Provide school route improvements. Engineering
associated with pedestrian
3. Improve visibility 3.1 Enhance crosswalks and sight lines to improve visibility of pedestrians (e.g.
between motor bump-outs). Engineering
fatalities and serious injuries.
vehicles and
pedestrians 3.2 Implement lighting/crosswalk illumination measures. Engineering
3.3 Provide signs, signals and/or flashing beacons to alert motorists that
Engineering
This data-driven, collaborative pedestrians are crossing.
4. Improve 4.1 Promote awareness and increase enforcement of existing laws regarding
approach will help Illinois achieve pedestrian and pedestrians’ right-of-way. Education
motorist safety
pedestrian fatality and A-injury awareness and 4.2 Increase equitable enforcement of existing laws that promote pedestrian safety Education/
behavior for pedestrians and other roadway users.
goals and ultimately drive Zero Enforcement
Fatalities to a reality. 4.3 Provide education, outreach, and training for all roadway users of the dangers of
exiting their vehicle (disabled vehicle, crash, etc). Enforcement
4.4 Implement pedestrian programs and include outreach to schools, churches, and
Education
senior centers.
4.5 Participate in the national discussion on pedestrian safety. Education
4.6 Encourage increases in state and local contributions for pedestrian facilities. Engineering
4.7 Continue to improve drivers education by incorporating components into

Education
licensure, including for CDLs.
5. Provide guidance 5.1 Provide guidance and criteria to assist state and local agencies in identifying
to planners and effective countermeasures for application under specific roadway, traffic volume,
designers to address and traffic speed conditions. Engineering
pedestrian safety
issues
Illinois Strategic Highway Safety Plan 2017 182 Pedestrian 85

Illinois Complaint Against The Illinois Department of Transportation

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Illinois Complaint Against The Illinois Department of Transportation

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Return Date: No return date scheduled

Hearing Date: 9/5/2019 10:00 AM - 10:00 AM

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

VERIFIED COMPLAINT FOR COMMON LAW

H. IDOT Is Satisfied With Little To No Northbrook Police Enforcement ....................... 18

PRAYER FOR RELIEF ...................................................................................................... 47

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

VERIFIED COMPLAINT FOR COMMON LAW

Acting Secretary of the Illinois Department of Transportation (“IDOT”), and IDOT,

Plaintiff R. Clifford Potter states as follows.

1. Plaintiff lives on Waukegan Road (Illinois Highway 43) in downtown Northbrook,

3. Defendant Omer Osman directs the activities of IDOT.

what he deems appropriate.

JURISDICTION AND VENUE

Voltz Road (“Waukegan Road Urban District” or “WRUD”) in Northbrook.

giving rise to the claims below occurred in Cook County.

NATURE OF THIS CASE

MPH speed limits in Urban Districts.

of more serious injury and death.

municipalities even at 25 and 30 MPH.

used on WRUD as a matter of law. Otherwise, as now, illegal discrimination is occurring

80 MPH, in ultra vires disregard of the speed limits.

center turn lane.

be done at far less cost to IDOT and Plaintiff.

with Illinois and federal law.

FACTS COMMON TO ALL COUNTS

as 90% of the traffic going by at speeds up to over 80 MPH.

necessary improvements on WRUD.

when State Representative Gabel requested IDOT to do so.

A. PART OF WRUD MAY SEEM LIKE A COUNTRY ROAD

(Front page, Speed Concepts: Informational Guide (USDOT, Federal Highway

those IDOT says should be modified and improved.

Northbrook, Representative Gabel called all of WRUD “downtown Northbrook” with a

(Group Exhibit 2))

driveways and a junior high school right next to the roadway.

funnel traffic into Chicago on municipal streets rather than on expressways.

trucks into this four-lane undivided unlimited access highway.

by Segment (April 1996) (excerpt) (Exhibit 3))

Road and other nearby Illinois highways.

state highway even ignoring the speeds involved.

points” from which traffic enters and exits the roadway.

C. NEARBY COMMUNITIES HAVE 30 MPH SPEED LIMITS ON BETTER HIGHWAYS

46. No neighboring highway is as unsafe or as unlivable as WRUD.

danger to both residents and those traveling on WRUD alike.

with vehicles driving at up to over 80 MPH in and near a downtown.

Road in Northbrook since 1996.

speed limits than WRUD.

Northbrook’s neighboring municipalities, have 30 MPH speed limits on more modern,

much safer stretches of state highways.

Waukegan Road, Downtown Glenview - Parking lanes on both sides protecting

parkways on both sides protecting pedestrians:

sidewalk protecting pedestrians with one access point in sight.

residential driveways in sight.

despite repeated opportunities to do so.

particulate pollution than faced by Plaintiffs’ Waukegan Road neighbors.

D. IDOT’S 40 MPH SPEED LIMIT IS MUCH MORE DANGEROUS THAN 30 MPH

recommended be substantially modified over two decades ago.

neighbors with a 30 MPH. It is also much higher at 30 MPH than at 25 MPH.

40mph • FOR A SAFER NYC !

Crashes Are Preventable.

drive on every day.

residents as IDOT has done in neighboring municipalities, IDOT has discriminatorily

walking and bicycling in and around downtown Northbrook with no consideration