March 12, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs
Attn via email: Eva Murray

Re:  MassDOT Snow and Ice Control Program EEA#11202

Dear Secretary Theoharides:

WalkBoston commented on MassDOT’s Environmental Status and Planning Report (ESPR) on Snow and Ice Control in 2018 and has continued to follow the agency’s efforts regarding the clearance of sidewalks, curb ramps and traffic islands that are under MassDOT’s jurisdiction. While we do believe that MassDOT’s staff agree that sidewalk snow clearance is an important safety, equity and mobility issue, we are disappointed in their lack of progress since 2018.

Our comments reiterate this importance and report on some of the work that WalkBoston has done to urge MassDOT to take more effective planning and operational steps.

As laid out by MEPA in 2018 (page 4), MassDOT’s scope relative to sidewalks was as follows:

“The DSW for the 2022 ESPR should include a response to comments received on the FESPR. In its comments on the DESPR, WalkBoston requested that the ESPR include more information about snow and ice control measures for pedestrian facilities. The FESPR noted that MassDOT will soon complete a statewide Pedestrian Transportation Plan that will include recommendations for improving pedestrian conditions affected by snow and ice. Consistent with MassDOT’s policy to promote alternate modes of transportation, including walking and bicycling, and implementation of its Complete Streets design program, the 2022 ESPR should provide a summary of the findings and recommendations of the Pedestrian Transportation Plan and describe any snow and ice control measures that will be implemented by MassDOT to improve pedestrian conditions. The DSW for the 2022 ESPR should identify any additional analyses or tracking of salt use associated with pedestrian facilities that will be included in the ESPR consistent with the scope and purpose of the SICP ESPRs.”

The Statewide Pedestrian Transportation Plan was completed in 2019 and very clearly called out sidewalk snow clearance as critically important, and as one of the responsibilities for MassDOT to lead on as a transportation and equity issue. It also stated that MassDOT needs to assume responsibility for sidewalk snow removal for some roadways that are under MassDOT’s direct care and control. The text of the Plan which describes these responsibilities is shown below (highlights provided by WalkBoston).

Introduction

With its abundance of historic town centers, compact neighborhoods, urban areas, and natural resources, Massachusetts is home to premier walking environments. However, conditions for walking vary widely from one place to another. A simple stroll can quickly turn challenging or even impossible in the face of discontinuous sidewalks, missing curb ramps, unplowed snow, or unsafe intersections.

Principles

Prioritize improvements for people walking by proactively addressing gaps and barriers that discourage walking and are known to increase likelihood of crashes. MassDOT shall address deficiencies– from sidewalks gaps and missing crosswalks, access to transit, and snow and ice removal, for example.

Initiatives

Initiative 5: Launch a year-round maintenance and operations plan for MassDOT-owned pedestrian facilities and support municipalities to do the same.

Year-round maintenance of pedestrian facilities ensures the continual comfort and safety of the people who use them, but also extends the lifespan of the facilities themselves. MassDOT has a comprehensive process for inventorying the condition of curb-to-curb roadway pavement and for clearing snow and ice on all roadways and bridges travelled by vehicles. This initiative establishes actions to add pedestrian facility maintenance and operations to this work. MassDOT is moving towards a proactive and systematic data collection strategy to identify facilities in need of attention. MassDOT has already gathered data on curb ramp condition as part of the Statewide ADA Transition Plan.

Actions

Action 2: Pilot a winter snow and ice removal initiative on pedestrian facilities in order to provide the basis for development of a comprehensive plan – and an understanding of potential barriers to make such a program permanent.

Measures for tracking progress (on Actions)

Note: Part of the initiative is defining the maintenance standards and operational plans for snow and ice removal that will apply to these measures.

• Percentage of MassDOT pedestrian facilities that are covered by regular snow and ice operations
• Equity check: Do certain populations live in areas where fewer pedestrian facilities are covered by regular snow and ice operations?

The Plan outlines significant and important attention to sidewalk snow and ice removal, and we applaud the Plan. However, MassDOT’s efforts to date have not improved sidewalk snow clearance rates on MassDOT-owned facilities. Our March 1, 2021 letter to MassDOT Highway Administrator Jonathan Gulliver is included below and outlines our disappointment in the progress since the 2019 Plan.

Specific comments regarding the Status Report that MassDOT submitted to MEPA in February 2021 

Page 2, Section 1.2 Organization and Format – We are disappointed that sidewalks are not called out here as a section and not mentioned as one of the issues to be addressed.

Section 2.1 Preliminary responses – A number of the preliminary responses are quite specific and note progress toward addressing the issues. Given the specificity of MassDOT’s Pedestrian Plan regarding sidewalk snow clearance, and the requirements in the MEPA Certificate, we think that MassDOT’s answer (shown below) is incomplete and does not accurately characterize the barriers described in a recent presentation by MassDOT to the Massachusetts Bicycle and Pedestrian Advisory Board (a Board established by legislation whose members are appointed by the Governor) where staff indicated that MassDOT had not been able to secure contractors to clear additional sidewalks, or enter into meaningful agreements with municipalities to clear MassDOT-owned facilities.

MassDOT Answer (page 6 of the update) – In the last few years, MassDOT has committed additional resources to provide snow and ice control on approximately 10% of the sidewalks adjacent to their roadways focusing on key areas with relatively high pedestrian usage. This effort is in the early stages of development and MassDOT will likely add more sidewalks into its winter maintenance program as resources become available. The status of this effort will be updated in the 2022 ESPR.

Following the MABPAB meeting (January 27, 2021) WalkBoston reached out to MassDOT staff to secure clarification on progress on sidewalk clearance. We followed this up with a letter to the Highway Administrator Jonathan Gulliver and are awaiting his response.

Forwarded message ———

From: Stacey Beuttell <sbeuttell@walkboston.org>

Date: Mon, Mar 1, 2021 at 11:12 AM

Subject: MassDOT Sidewalk Snow Removal Pilot

To: <Jonathan.Gulliver@dot.state.ma.us>

Cc: Jacqueline DeWolfe (DOT) <jacqueline.dewolfe@state.ma.us>

Hi Jonathan. 

I wanted to check in with you regarding MassDOT’s sidewalk snow shoveling pilot program that is now in its second year. Several members of the MassDOT Operations and Maintenance team recently updated MABPAB on the current status of the program and relayed the many barriers that have prevented MassDOT from entering into meaningful agreements with vendors to clear MassDOT-owned sidewalks. They reported that only 8.7% of MassDOT-owned sidewalks are currently being cleared by either MassDOT staff or by contractors. Furthermore, they reported that despite making changes to the sidewalk snow removal RFP this year, no qualified vendors applied for the contract. So, needless to say, people have been unable to walk safely on most MassDOT sidewalks throughout this snowy winter. I’m reaching out to see if there are ways WalkBoston can help with this issue, one that we feel is vitally important for year-round safe walking across the state.

I followed up with Jackie DeWolfe who suggested that I reach out to you. She reiterated MassDOT’s commitment to clearing sidewalks of ice and snow, and suggested that some of the barriers are outside of MassDOT’s control – for example, lack of labor market for sidewalk snow removal; and varying rules and capacities within municipalities to clear sidewalks. WalkBoston is eager and excited to find ways that we can support MassDOT and we are hoping to better understand the contract/municipal agreement issues and to get more sidewalks plowed. What next steps do you suggest we take to better understand the barriers and MassDOT’s work to date to overcome them? I would be happy to set up a Zoom call to discuss these questions with you. 

We know that this is an incredibly complex issue to solve. We know that you are likely as disappointed that the pilot program has now stalled for two snow seasons, as we in the advocacy community are, due to vendor/contract issues. I look forward to talking with you and discussing ways we can support forward movement on this important MassDOT priority.

Thanks Jonathan. I hope you have a good week.

Stacey Beuttell

We urge MEPA to require MassDOT to include specific, trackable and documented progress toward meeting the scope of pedestrian needs in its next filing on the MassDOT Snow and Ice Control Program, and to use its own Pedestrian Plan commitments as the baseline for reporting.

Thank you for the opportunity to comment on this critical issue for the safety, equity and mobility of Massachusetts residents.

WalkBoston would be pleased to answer any questions you may have about our comments.

Sincerely,

Stacey Beuttell                                                                  Wendy Landman
Executive Director                                                           Senior Policy Advisor