What's Incomplete About Complete Streets?

Although hundreds of states and local governments have adopted Complete Streets policies, American streets keep getting more dangerous for walkers and cyclists. What's missing from Complete Streets policies?

5 minute read

July 10, 2023, 7:00 AM PDT

By Michael Lewyn @mlewyn


Protected bike path with raised curb in Indianapolis, Indiana

A protected bike path in Indianapolis, Indiana. | Alan / Adobe Stock

When I was at the Congress for The New Urbanism conference a month ago, one of my fellow New Urbanists came up to me and said that I should write about the failure of the “Complete Streets” movement. He mentioned that even though many municipalities had adopted such policies, the persistence of overly wide roads and the recent rise in pedestrian fatalities suggests that perhaps cities were just ignoring their own laws. I responded that perhaps these policies are so vague and permissive that they don’t really force city transportation agencies to change the status quo.

To see if my guess was right, I decided to take a look at a few of the older Complete Streets policies. In 2012, Smart Growth America ranked municipal Complete Streets policies. I decided to begin by looking at a not-very-good policy: that of San Antonio, Texas, which ranked fifth worst among dozens of municipal policies passed by elected boards. The San Antonio policy begins with a fine general statement of objectives, stating that a “complete” street is one that satisfies the needs of all users, including not just drivers but walkers, cyclists, and transit users (Sec. 1A). 

That policy also states that the context of each street must be considered—that is, the level of traffic on a street and its function (Sec. 1B) and whether the street is residential or commercial (Sec. 1C). But here, the policy gives bureaucrats too little guidance to be useful. Should cities “complete” the busiest commercial streets, so walkers and cyclists can reach shops and jobs? Or should reforms focus on the quietest residential streets, so that people can walk or bike for exercise? San Antonio’s policy doesn’t tell us.

In fairness, San Antonio’s policy does have a section on commercial streets. The section states that travel by walking and cycling “will be considered in the construction and reconstruction of roads” (Sec. 4A), whatever that means. More promisingly, the section adds that travel on commercial streets “will be enhanced so that pedestrians may travel in comfort and safety … and vehicles have convenient access and travel at speeds safe for all users.” (Sec. 4B). 

But what happens if there is a conflict between vehicle convenience and “speeds safe for all users?”  San Antonio has numerous streets that have five or more lanes, and that appear to be designed for cars going 50 or 60 miles per hour, fast enough to easily kill a pedestrian.* This design was certainly convenient for vehicles, but it did not look particularly safe or comfortable for pedestrians or cyclists. The San Antonio policy doesn’t tell bureaucrats how to balance these considerations, and thus gives them ample room to leave these streets the way they are. Moreover, the policy is limited to “construction and reconstruction of roads,” but how frequently will a street like Northwest Military Highway be reconstructed?  

More generally, the policy says that the city must “balance the costs of construction with benefits to the community” (Sec. 5C). This seems like a reasonable rule, but weren’t cities balancing these considerations long before they adopted “Complete Streets” policies?

Even if the streets of San Antonio are more dangerous for walkers than they were in 2012, there is no reason to believe that the city is violating its Complete Streets policy. A more plausible inference is that the policy is so vaguely worded that it really doesn’t require the city to change its streets at all.

What about a highly rated Complete Streets policy? In 2012, Smart Growth America rated Indianapolis’s policy number 1 in the nation. Indianapolis’s 2012 policy is better than San Antonio's in a variety of ways: for example, it uses some mandatory language, orders the city to create quantifiable performance measures, and specifically applies to “major maintenance” (as well as new construction and reconstruction). 

In some ways, the policy has worked: over the last decade or so, the city has built 100 miles of bike lanes and a million linear feet of sidewalks. Clearly, the city is not ignoring its Complete Streets policy. Yet the streets haven’t gotten safer: 150 pedestrians have died from car crashes over the past five years, as opposed to 100 in the preceding five years.

What’s missing? First of all, even the best Complete Streets policy can't solve the problem of fiscal scarcity.  Even in a city committed to Complete Streets, street redesign must fight for public dollars with other worthy goals such as education and public safety. As a result, Indianapolis's improvements are a drop in the bucket. The city maintains 3,400 miles of streets and roads, so its 100 miles of bike lanes affect only 3 percent of the city. Similarly, 2,000 miles of the city's roads still lack sidewalks. 

Second, the quantitative benchmarks seem to focus on sidewalks and bike lanes (Sec. 431-806), and the policy doesn’t mention traffic calming or similar policies. So if the city had a six-lane road with traffic going 60 miles per hour, the Complete Streets policy would not affect that road except to the extent necessary to build a sidewalk or a bike lane.** Thus, even the best Complete Streets policies don't really address some of the most dangerous features of American street design.

So are Complete Streets policies useless? Not really. Indianapolis's successes show that a well-drafted policy can create some very modest benefits for the cycling and walking public. It's not a revolution, but it's a start.

*The original version of this article referenced NW Military Highway- but a reader informed me that that street is a state road, and is thus beyond the control of the city.  However, the city has numerous streets that fit this description and are not on a list of state roads in San Antonio.  For example, parts of Culebra Road have six lanes (see 8389 Culebra on Google Street View for an example). 

**Indianapolis recently adopted a new complete streets policy with more detail (referenced at the bottom of this article). But since this post is primarily about the deficiencies of older policies, an evaluation of the next generation of complete streets policies is best left for another day. 


Michael Lewyn

Michael Lewyn is a professor at Touro University, Jacob D. Fuchsberg Law Center, in Long Island. His scholarship can be found at http://works.bepress.com/lewyn.

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