Category: Comment Letter

Testimony against Sidewalk Robot Bills (H3331, H3417, S2228)

Testimony against Sidewalk Robot Bills (H3331, H3417, S2228)

October 27, 2023 

Joint Committee on Transportation
Brendan Crighton, Senate Chair
Room 109-C
Boston, MA 02133

William Straus, House Chair
Room 134
Boston, MA 02133

RE: Testimony against Sidewalk Robot Bills (H3331, H3417, S2228)

Dear Chairman Crighton and Chairman Straus,

WalkMassachusetts is a non-profit organization that works to make walking safer and easier in Massachusetts to encourage better health, a cleaner environment and more vibrant communities. Founded in 1990 as WalkBoston, we changed our name in April 2023 to better reflect the work we’re doing across the Commonwealth alongside community partners. LivableStreets advocates for practical, people-centered transportation systems in Metro Boston that can dismantle invisible barriers that divide neighborhoods, communities, and people.

We are concerned about legislation that would give robots the same rights to public sidewalks and walkways as pedestrians (H3331, H3417, S2228). Sidewalks, crosswalks, and other walkways across the Commonwealth currently fall short of meeting the needs of people of all ages and abilities, as evidenced by the increasing number of pedestrians killed every year.

Using MassDOT data, WalkMassachusetts released a crash report earlier this year which found that in 2022, 435 people died in traffic crashes in Massachusetts, including 101 people walking. Of the 351 cities and towns in Massachusetts, 60 communities had a fatal pedestrian crash in 2022, and older adults were hit and killed at a higher rate than those in other age groups. 71% of fatal pedestrian crashes took place in Environmental Justice Census Block Groups. The report can be found at 

Two sessions ago (March 2019), we testified against a ‘mobile carry device’ bill similar to H3417/S2228. We are broadly concerned that regulations allowing these devices could open the door to privatization of the public way. More specifically, we are troubled about the impacts these vehicles can have on the safety and comfort of pedestrians, young and old, and of people using mobility devices.  A 90-lb device that can carry up to 45-lbs of goods traveling at 12.5 miles per hour should not operate on the sidewalk; instead, it belongs in the street. Even more concerning is H3331, which would allow a 550lb ‘personal delivery device’ to operate at 10 miles per hour on sidewalks. It is unclear what the total weight of this much larger device would be, since the bill notes that this weight excludes cargo. At this weight and speed, the likelihood of a pedestrian injury is high–and likely higher for people who don’t move as fast or cannot see or hear these devices coming down the sidewalk.

We applaud efforts from the private sector for looking to offer deliveries using smaller vehicles. Oversized vehicles are a danger to people walking, biking, and driving. However, if delivery companies are concerned about the risk of their 550 pound vehicles getting struck while traveling on local streets, the answer cannot be to move them to the sidewalks.

Our shared vision for safe streets points to a longstanding need to increase funding for Chapter 90 and MassDOT’s competitive funding programs, including Safe Routes to School, Complete Streets, and the Shared Streets and Spaces program. Additionally, there needs to be a strong emphasis to encourage the use of these funds for traffic-calming, sidewalk construction, and other similarly walk-friendly infrastructure. Every reconstruction project should be a Complete Streets project, not just projects that receive money through the Complete Streets funding program. These oversubscribed programs allow communities to implement traffic calming measures and street designs that accommodate a wider range of smaller vehicles for deliveries and transportation.

We appreciate the opportunity to comment, and would be happy to work with any proponent to offer feedback.


Brendan Kearney
Co-Executive Director, WalkMassachusetts

Catherine Gleason
Public Policy Manager, LivableStreets Alliance

Comment Letter on Proposed Patrick Subaru Dealership, EEA #16747

Comment Letter on Proposed Patrick Subaru Dealership, EEA #16747

September 11, 2023

Secretary of the Executive Office of Energy & Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

Attn: MEPA Office, Alexander Strysky (via email)

Re: Comments on Proposed Patrick Subaru Dealership, EEA #16747

Dear Alex:

WalkMassachusetts (previously known as WalkBoston) is Massachusetts’ primary pedestrian advocacy organization, working across the Commonwealth with a vision for Massachusetts where people walking – no matter their race, identity, age, ability, or lived experience – feel safe, connected, and valued on our streets and sidewalks. We are writing with comments for the proposed Patrick Subaru Dealership, EEA #16747.

The project site is located at 701 Boston Turnpike in Shrewsbury, at the corner of Route 9 and South Street. There was a fatal hit & run crash at this location on October 30, 2022 just after 10pm, where 20-year old Ghufran Mutar was struck and killed while crossing Route 9 at the intersection with South Street on her way home from working at CVS. Our fatal crash report released earlier this year showed that this was one of 101 fatal crashes involving pedestrians in 2022, of which 71% were located in environmental justice census block groups, which includes this location.

According to the MassDOT Road Inventory, Route 9 is under MassDOT jurisdiction, and South Street is under local jurisdiction. Route 9 is a two-way divided roadway, with two lanes in each direction and additional left turn lanes at the intersection. There are no sidewalks on either street, and no crosswalks for any leg of the intersection. Route 9 is a barrier to safe walking and biking in many communities across the Commonwealth. The 2023 Strategic Highway Safety Plan prioritizes collaboration: “Beyond state-municipal coordination, this plan also seeks to highlight how external partners and private industry can contribute to improving safety.” We encourage the proponent to include a sidewalk along the project’s South Street frontage, and we encourage the proponent, municipality, and MassDOT to add crosswalks, ADA ramps, and pedestrian signals to make crossing Route 9 at this intersection safer and accessible.

Thank you,

Brendan Kearney
Co-Executive Director, WalkMassachusetts

Exploring East Boston with Caminatas Seguras

Exploring East Boston with Caminatas Seguras

On June 13th 2023, WalkMassachusetts joined East Boston community members on a walk led by GreenRoots, a non-profit dedicated to improving the local urban environment and public health, with a focus on Chelsea and East Boston. The walking group Caminatas Seguras meets weekly on Tuesdays to help promote walking as a way to enjoy local public spaces, be physically active, and build connections with residents who have historically been excluded from public decision making processes.

Senior Program Manager Iolando Spinola and Summer Intern Chiara Palagi join GreenRoots and Caminatas Seguras on a walk through East Boston.

Around 25 participants, including Senior Program Manager Iolando Spinola and Summer Intern Chiara Palagi, began at Piers Park, a local space overlooking the Boston Harbor. The group engaged in lively conversations throughout the walk, with topics including new developments in the area, recent and upcoming community events, and even just catching up with one another on an individual level. Passionate GreenRoots volunteers provided historical context and relevant information about the spots along the path.

John Walkey of GreenRoots gives community members historical context on spots encountered during the walk.

The day’s route passed by landmarks such as the ICA Watershed gallery and the Navy Fuel Pier park. With a breathtaking view of the Boston skyline across the harbor, the park’s lush green spaces and well-maintained paths provided the perfect setting for our walk.

Members of the East Boston community admire the view from Navy Fuel Pier park.

Our walk culminated at East Boston Memorial Park, giving GreenRoots volunteers the opportunity to engage with the community members and share upcoming events and opportunities for involvement. Information and flyers were distributed bilingually, showcasing local initiatives, events, and programs aimed at addressing pressing issues in the neighborhood while involving and empowering residents.

Through walking, conversation, and shared experiences, the bonds between community members and activist groups grow stronger every week in Caminatas Seguras, paving the way for a more connected and engaged East Boston. WalkMassachusetts is grateful to have had the opportunity to join GreenRoots and Caminatas Seguras for this experience.

WalkBoston Comments on 2022 MassDOT Snow and Ice Control Program EEA#11202

WalkBoston Comments on 2022 MassDOT Snow and Ice Control Program EEA#11202

February 6, 2023

Secretary Rebecca Tepper
Executive Office of Energy and Environmental Affairs

Attn via email: Eva Vaughan

Re:  2022 MassDOT Snow and Ice Control Program EEA#11202

Dear Secretary Tepper:

WalkBoston commented on MassDOT’s Environmental Status and Planning Report (ESPR) on Snow and Ice Control in 2018 and again in March 2021. Our 2021 comments were incorporated into the Certificate issued by EOEEA in 2021.

WalkBoston has continued to follow MassDOT’s efforts regarding the clearance of sidewalks, curb ramps and traffic islands that are under the agency’s jurisdiction, and we are pleased that the 2022 ESPR includes several new commitments to sidewalk snow clearance.

One important step that MassDOT has taken since 2021 is the provision of grant funding of up to $50,000 to help municipalities purchase snow removal equipment for pedestrian and bicyclist facilities through its Shared Streets and Spaces Grant Program. While not directed to MassDOT owned sidewalks, this program should help to increase sidewalk snow clearance on municipal sidewalks.

As stated on page 15 of the ESPR, approximately 43% of MassDOT roads have adjacent sidewalks amounting to approximately 1,300 miles of sidewalks located mostly in the central village and downtown areas of various communities. The new steps called out by MassDOT in the ESPR (pages ES-5 and 15) are the following:

  • New for the 2022/23 winter, MassDOT plans to hire more “seasonal” snow and ice employees that report directly to MassDOT to help with sidewalk clearing as well as other activities.
  • MassDOT will continue to evaluate vendor reimbursement rates and pay codes to enlist more contractors for sidewalk maintenance services and better reflect the variable snow removal efforts for large storms versus smaller storms.

When MassDOT reports on the outcomes of its 2022 ESPR we ask that the following information be included so that WalkBoston and others can see how successful the new efforts are at providing safe and accessible sidewalks.

  1. Provide a map showing the location of the 1,300 miles of MassDOT sidewalks, and indicate which of these miles were covered by work orders for clearance by MassDOT or its contractors.
  2. Include sidewalk clearance responsibilities in the table showing MassDOT SICP roles and responsibilities (Table 1.2 on page 6 of the report)
  3. Provide information about the cost of sidewalk snow clearance provided by MassDOT or its contractors – similar to that provided in Table 1.9 for lane miles.

We look forward to continuing to work with MassDOT on this important public safety and mobility issue.

Best regards,

Brendan Kearney

Deputy Director of Advocacy, WalkBoston

WalkBoston Testimony for Somerville Traffic Commission hearing, 12/20/2022

WalkBoston Testimony for Somerville Traffic Commission hearing, 12/20/2022

Submitted in advance on 12/20/2022 via email.

My name is Brendan Kearney, I’m the Deputy Director of Advocacy for WalkBoston, the statewide pedestrian advocacy organization in Massachusetts. The term “jaywalking” was created by the auto industry in the 1920s to divert blame from drivers who were hitting and killing people. A century later it has proven to be a highly successful marketing effort.

I’m writing to support the petition that restores the right for people walking to cross the street when it is safe to do so, even where a crosswalk or traffic signal is not present. We acknowledge that people walking must exercise reasonable care for their own safety and yield to people driving if a pedestrian is not crossing in a crosswalk. 

We think it is important to share what this petition isn’t: this is not the right to walk or run into the path of a vehicle that is so close that it is impossible for the driver to yield the right of way (Section 12-4(a) in Somerville’s Traffic Regulations). 

There are significant equity concerns around jaywalking enforcement. Jaywalking laws contribute to racial profiling. A report by ProPublica and Florida-Times Union found Black people in Jacksonville, Fla. were three times as likely to be stopped and cited as white people. Similar patterns have been seen elsewhere; Streetsblog NYC reported that nearly 90 percent of people issued jaywalk citations in New York in 2019 were Black and Brown. In response, efforts to decriminalize jaywalking have been mounted in a number of places, including Virginia and California.

This proposed Somerville regulation change reflects how many people already use our streets in Massachusetts and how our communities are designed. There is not always a crosswalk where people want or need to cross the street. There have been ill-conceived bills at the State House over the last few sessions that would effectively make it illegal to cross anywhere outside a crosswalk. WalkBoston will continue to testify and speak out against those preposterous bills, and we encourage you to as well. Any proposed bills to crack down on jaywalking places an unnecessary burden on pedestrians without making anyone safer. 

I am grateful to residents in Somerville for moving this effort forward, and encourage you to adopt this change. 

Brendan Kearney
Deputy Director – Advocacy, WalkBoston