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Design Standard Readability

Fry readability formula

How Consistent Are the Best-Known Readability Equations in Estimating the Readability of Design Standards?

Shixiang Zhou & Heejin Jeong
Industrial and Operations Engineering Department, University of Michigan, Ann Arbor, MI, USA
Transportation Research Institute Driver Interface Group
Department of Industrial and Operations Engineering, University of Michigan, Ann Arbor, MI, USA


Abstract.  Research problem: Readability equations are widely used to compute how well readers will be able to understand written materials. Those equations were usually developed for nontechnical materials, namely, textbooks for elementary, middle, and high schools. This study examines to what extent computerized readability predictions are consistent for highly technical material – selected Society of Automotive Engineers (SAE) and International Standards Organization (ISO) Recommended Practices and Standards relating to driver interfaces. Literature review: A review of original sources of readability equations revealed a lack of specific criteria in counting various punctuation and text elements, leading to inconsistent readability scores. Few studies on the reliability of readability equations have identified this problem, and even fewer have systematically investigated the extent of the problem and the reasons why it occurs.  Research questions:

(1) Do the most commonly used equations give identical readability scores?
(2) How do the scores for each readability equation vary with readability tools?
(3) If there are differences between readability tools, why do they occur?
(4) How does the score vary with the length of passage examined?

Method: Passages of varying lengths from 12 selected SAE and ISO Recommended Practices and Standards were examined using five readability equations (Flesch-Kincaid Grade Level, Gunning Fog Index, SMOG Index, Coleman-Liau Index, and Automated Readability Index) implemented five ways (four online readability tools and Microsoft Word 2013 for Windows). In addition, short test passages of text were used to understand how different readability tools counted text elements, such as words and sentences. Results and conclusions: The mean readability scores of the passages from those 12 SAE and ISO Recommended Practices and Standards ranged from the 10th grade reading level to about 15th. The mean grade reading levels computed across the websites were: Flesch-Kincaid 12.8, Gunning Fog 15.1 SMOG 12.6, Coleman-Liau 13.7, and Automated Readability Index 12.3. Readability score estimates became more consistent as the length of the passage examined increased, with no noteworthy improvements beyond 900 words. Among the five readability tools, scores typically differed by two grade levels, but the scores should have been the same. These differences were due to how compound and hyphenated words, slashes, numbers, abbreviations and acronyms, and URLs were counted, as well other punctuation and text elements. These differences occurred because the sources for these equations often did not specify how to score various punctuation and text elements. Of the tools examined, the authors recommend Microsoft Word 2013 for Windows if the Flesch-Kincaid Grade Level is required.



Standards Virginia

“Natural Bridge Virginia” (1880) / David Johnson

As we explain in our ABOUT, we continur development of the cadre of “code writers and vote-getters” begun at the University of Michigan in 1993.  Code writers and vote getters are the true expert witnesses to the social negotiation of technical change.  They are typically not red-tape makers.  They are leaders in reconciliation of the competing requirements of safety and economy in the largest non-residential building construction market in the United States.

We now drill down into state and local adaptations of nationally developed codes and standards that are incorporated by reference into public safety statutes and sustainability legislation.  Every state will be approached with respect for its history, culture, governance regime, asset-base and network of expertise.

Standards Michigan remains the “free” home site but state-specific sites such as Standards Virginia will be accessible to user-interest code-writers and vote-getters.   Please send bella@standardsmichigan.com a request to join one of our mailing lists appropriate to your interest for #SmartCampus standards action in the State of Virginia.

Virginia Uniform Statewide Building Code

Department of Professional and Occupational Regulation

Electronic Municipal Market Access / State of Virginia

Standards Virginia Workspace


Who Is the User-Interest?

University of Michigan

We are not a non-profit.

We are not a blog.

We are not a proxy for incumbents.

We are not standards evangelizers .

We are not “Oracle of Change” trendsniffers.

We do not claim to be an opinion aggregator

We get results.

Visit us  across from the University of Michigan campus. 


The Standards Michigan logo  — designed about ten years ago during the 25-year tenure of the original University of Michigan standards advocacy enterprise – reflects the three interest groups in the global standards system generally, and the United States specifically.  It was inspired from experience advocating safety and sustainability concepts in the National Electrical Code and coming to understand that the National Fire Protection Association — which was then, and remains so — the most rigorous standards setting organization in the United States was having difficulty meeting the ANSI balance requirements [§2.3].  If NFPA was having trouble getting users to participate, what was it like for other ANSI accredited standards setting organizations?

At the University of Michigan Ross School of Business,  Joe Bhatia, Chairman of the American National Standards Institute drove home the point to the education industry which is the foundation of all industries in every nation:

Archive / UM Welcomes ANSI 2014

Still, the private standards system, a relatively small part of the global standards system generally, is still better than having leading practice determined by politicians, their staffs, their contractors and their donors.

Touchy subject.

Join us today when we look at one or two technical committee rosters — and where in the world their meetings are held and how often.  If there is time, we will review the balloting patterns on one or two technical topics which have significantly contributed to making education communities safer, simpler, lower-c0st and longer lasting.  When you do that for education communities; you are effectively doing it for all other industries.

Workspace / ANSI

*We time-stamped the hashtag #WiseCampus on Twitter about 3 years ago; knowing that the half-life of buzzwords needed by education industry trade associations to drive conference revenue has grown shorter.   The COVD-19 pandemic is enough of a singularity that we are inspired us to be more visible with it in our Twitter feed.

Antitrust Regulators & Standards Development Organizations

“The Bosses of the Senate”, a cartoon by Joseph Keppler depicting corporate interests—from steel, copper, oil, iron, sugar, tin, and coal to paper bags, envelopes, and salt—as giant money bags looming over the tiny senators at their desks in the Chamber of the United States Senate. CLICK ON IMAGE




To carry out our mission to make education facilities safer, simpler, lower-cost and longer-lasting we are sensitive to the mission of all market actors in this $300 billion (and largely, non-profit) space.  Standards Michigan is a for-profit, limited liability corporation with an evolving business model that seeks to apply any tool — and invent one — to accomplish its objective.   With its origin and inspiration from a University of Michigan business and finance enterprise in 1993; we are skilled in asserting the user-interest in the global standards system and have a solid and verifiable track record of success making safe and sustainable cost reductions possible.  See our ABOUT.

Staying in business means staying in your lane and being sensitive to competitors who can become collaborators on specific issues.   The collaboration may not last long, or be very limited in scope, but it is a credit to the global standards system that a framework for collaboration and competition is generally fixed and honored in the courts.

The education industry is a discoverer and promulgator of new knowledge.  It has a social obligation to contribute to the culture of collegiality to transfer to every nation’s youth as inherited wisdom.  Simultaneous competition and collaboration opens onto a minefield of sensitivities, however.

We frequently refer to incumbent stakeholders, or “verticals” when we frame public commenting opportunities presented by standards developing organizations (SDOs) of any configuration (accredited, consortia, or open source).   We have a search algorithm that runs continuously and picks up commenting opportunities by SDO’s twice a day.  Several times a year we update our list of education industry trade associations; most of them not standards developers*.  These trade associations have constraints; the need to tip-toe around the laws that regulate their activity.

So do trade associations aligned with the academic side of the education industry, as can be observed in the December 2019 case  U.S. v. National Association for College Admission Counseling.   Perspective on this case appears in an article written by a partner in the first name in US standards law Gesmer Updegrove‘s blog: CONSORTIUMINFO.ORG

Antitrust Regulators Turn Attention to Standards Organizations

Russ Schlossbach | March 25, 2020

Along with the Federal Trade Commission the Department of Justice in Washington, D.C. is the public enforcer of antitrust law.

* The education industry trade associations that are ANSI standards developers are the direct result of University of Michigan facility operations catalyzing balance in leading practice discovery.  The primary example is Total Cost of Ownership standard developed by APPA Leadership in Education.



National Cooperative Research and Production Act of 1993



Public Procurement & Private Certification

“View of Boston Harbor from Dorchester Height” | Thomas Doughty (1843) | Yale University Art Gallery

In formulating a response to the expansion of the scope of ANSI/ASHRAE/IES Standard 90.1-2016 — Energy Standard for Buildings Except Low-Rise Residential Buildings well beyond the building envelope onto entire building sites — such as entire campuses — we revisit recent, relevant research into the effect of market-making by accredited standards developers.  Our interest lies in the degree to which their action contributes to the safety and sustainability agenda of the $300 billion education facility industry in the United States.

One of the most enlightening discussions of sustainability-related certification programs is provided by Tim Simcoe at the Questrom School of Business.    From the research abstract:

“Governments increasingly use their purchasing power to promote environmental policy objectives. We study the relationship between public municipal green-building procurement policies and diffusion of the US Green Building Council’s LEED certification program. We find a strong link between public green building procurement plans and voluntary private adoption of the LEED standard. We also observe an increase in LEED professional accreditation in communities that adopt a green procurement policy. We suggest that public policy may spur private certification by resolving the coordination problem that arises among developers and local building professionals in the diffusion of a new certification program”





Tree Care

“Landscape with a clump of trees” | Théodore Rousseau (1844)


“Keep a green tree in your heart

and perhaps a singing bird will come”. 

— Chinese proverb


The condition of campus gardens, trees and landscaping is a central element of ambiance, brand identity, environmental instruction and even revenue tied to charitable donations.   The Tree Care Industry Association (TCIA) is an ANSI-accredited standards developer and posts its public commenting opportunities on its consensus products at the link below:

Current Projects & Public Review Periods

The TCIA standard — A300 Tree Care Operations – Tree, Shrub, and Other Woody Plant Management – Standard Practices is noteworthy, and summarized below:

Scope: Support Systems standards are performance standards for the installation of cabling, bracing, guying, and prop systems in trees and woody shrubs. It is a guide for drafting supplemental support system specifications for consumers as well as Federal, state, municipal, and private authorities including property owners, property managers, and utilities.

Project Need: Revision needed to review and incorporate changes in industry standard practices, as appropriate, since the approval of the current standard.

Stakeholders: Tree Care industry, Green industry, arborists, Land Care industry, landscape architects, property managers, utilities, urban planners, consumers, government agencies.

The comment period for this product closed in late February but, as with all ANSI-accredited standards developers, it invites public participation.   Data and war stories are almost always welcomed.  We encourage our colleagues in business units responsible for lawns, trees, gardens and pathways to participate in the TCIA standards development process (Learn more HERE).  We encourage their bosses to cover their travel costs and professional time to participate in the face-to-face TICA meetings.

Stakeholders in any interest category may communicate directly with Amy Tetreault at the Tree Care Industry Association, (603) 314-5380, atetreault@tcia.org, 136 Harvey Rd # 101, Londonderry, NH 03053.

We devote an hour every month to codes and standards that should be guiding the safety and sustainability agenda of the workgroups responsible for the condition and appearance of campus landscaping, lawns, gardens, sidewalks, lighting and trees.   See our CALENDAR for the next Lawn & Garden breakout teleconference; open to everyone.


Issue: [Various]

Category: Landscaping & Exterior

Colleagues: Mike Anthony, Jack Janveja, Richard Robben


Archive / Tree Care Industry Association


Readings / Wicked Problems

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United States Standards Strategy

An American flag mural, 2012. Photograph by Carol M. Highsmith. Library of Congress


The American National Standards Institute (ANSI) has released for public comment the first draft version of the 2020 update to the United States Standards Strategy (USSS). Updated every five years, the USSS describes the principles and tactics that guide how the United States develops standards and participates in the international standards-setting process. Input on the draft is requested by August 31, 2020.

The USSS serves as a statement of purpose resulting from a reexamination of the principles outlined in the Strategy. In its role as coordinator of the U.S. private-sector standardization system, ANSI leads a review and update to the USSS every five years to assure that the document continues to meet the needs of diverse U.S. interests, and reflects technological advancements, industry growth areas, national and international priorities, and updates to relevant U.S. government policy.

Integral to the review and update, announced in late 2019, ANSI is seeking broad input from stakeholders, including government, industry, standards developing organizations (SDOs), consortia, consumer groups, and academia. A USSS task force –comprised of volunteers and members of ANSI’s Board representing SDOs, government, industry, and consortia –is assisting ANSI staff in managing input received. The first draft of the 2020 USSS incorporates comments received from ANSI’s member forums, policy advisory groups, committees, and the broader stakeholder community through June 30, 2020.

“I encourage broad public comment so that the U.S. Standards Strategy can reflect the input of all affected voices,” said ANSI president and CEO S. Joe Bhatia. “The U.S. private-sector-led standardization system is strong because it involves the participation of all affected parties, and the Strategy is intended to reflect this strength and diversity.”

Following the close of the comment period on August 31, an updated draft will be developed, discussed during World Standards Week 2020, and ultimately forwarded to the ANSI Board of Directors for approval at its year-end meeting.

Instructions for Providing Comment

Please send all comments on the first draft version of the 2020 USSS update to USSScomments@ansi.org by COB on Monday, August 31.  All submissions should indicate the specific section(s) of the USSS to which each comment refers. In particular, commenters are encouraged to consider the following questions:

  1. What elements of the draft 2020 USSS are most important/useful?
  2. What elements may be missing that should be addressed in the update?

For reference, access the current USSS (approved December 2015)Following publication of the updated USSS in early 2021, ANSI will work with all stakeholder communities to broadly publicize the Strategy, identify action items, and promote broad use and implementation.  The 2020 update is the fourth review of the Strategy, which was first published in 2000.

For more information contact Jana ZabinskiDirector, Communications and Public Relations, American National Standards Institute, (zabinski@ansi.org)

We maintain all ANSI public consultation notices on the standing agenda of our Federal teleconferences.   See our CALENDAR for the next online meeting

Issue: [20-158]

Category: Federal

Colleagues: Mike Anthony, Christine Fischer, Jack Janveja, Richard Robben, Lee Webster


Education Industry Trade Associations

“The Seven Liberal Arts” | Giovanni di Ser Giovanni Guidi

Join us today at 11 AM/ET when we review the economic activity of “niche verticals” in the education community domain. The surprising number of them; their appetite for money, their inspiration in political agendas and their claims of hegemony (found in the letters they write to legislators) provides insight into the competing requirements of a domain that is a “business” and a “culture”.

Unlike the economic activity of manufacturing and labor sector which have coalesced their lobbying into a few (less than 10) non-profits, the education industry has 1oo’s of these associations.  Every branch and leg of a typical school district, college and university, has evolved a non-profit trade association.  Maybe there are too many; maybe there are not enough.  Maybe this is the normal course of leading practice discovery.  We reflect upon these possibilities — and welcome others — for digital youth.

We have maintained this topic in our wheelhouse for many years because it offers insight into how redundancies in human resource management may chart a path toward lower cost.

Use the login credentials at the upper right of our home page.

Trade Associations for the education industry

Standing Agenda / Education Industry Trade Associations

Smart Cities: Wicked Problems

“Oxford from the River with Christ Church in the Foreground” | William Turner (1820)

Smart cities: moving beyond urban cybernetics to tackle wicked problems

Cambridge Journal of Regions, Economy and Society, Volume 8, Issue 1, March 2015 | “The Smart City”


Abstract. This article makes three related arguments. First, that although many definitions of the smart city have been proposed, corporate promoters say a smart city uses information technology to pursue efficient systems through real-time monitoring and control. Second, this definition is not new and equivalent to the idea of urban cybernetics debated in the 1970s. Third, drawing on a discussion of Rio de Janeiro’s Operations Center, I argue that viewing urban problems as wicked problems allows for more fundamental solutions than urban cybernetics, but requires local innovation and stakeholder participation. Therefore the last section describes institutions for municipal innovation and IT-enabled collaborative planning.




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