Comment Letter – Page 19 – WalkMassachusetts

Re: Comments on H3126/S2069 An Act Relative to Mobile Carry Devices

By WalkMassachusetts | March 28, 2019

March 28, 2019

Joint Committee on Transportation
Joseph A. Boncore, Senate Chair
State House, Room 112
Boston, MA 02133

Joint Committee on Transportation
William Straus, House Chair
State House, Room 134
Boston, MA 02133

Re: Comments on H3126/S2069 An Act Relative to Mobile Carry Devices

Dear Chairman Boncore and Chairman Straus,

WalkBoston is Massachusetts’ main pedestrian advocacy organization, working to make walking safer and easier in Massachusetts to encourage better health, a cleaner environment and more vibrant communities. LivableStreets Alliance advocates for innovative and equitable transportation solutions that create safe, affordable and convenient options for everyone in Metro Boston. We write to provide the Committee with our comments on H3126/S2069, “An act relative to mobile carry devices.”

If we are to continue to build more livable cities and towns across Massachusetts, we must ensure the sidewalks are made for people of all ages and abilities. A 90-lb device that can carry up to 45-lbs of goods traveling at 12.5 miles per hour does not belong on the sidewalk, and instead should be in the street.

At a high level, we are also concerned that these regulations could open the door to the privatization of the public way: our sidewalks. The most sought-after space in our cities is at the curb. Cities on the West Coast continue to grapple with transportation technology issues a few months in advance of us, including the testing of autonomous delivery robots. The latest example we’ve heard from Walk San Francisco includes a proposal from a tech food delivery company to use robots to continuously operate on a sidewalk route to pick up multiple orders from a store and deliver them 2-3 blocks away to a waiting delivery driver in a car.

This legislation leaves many questions:

The language “primarily for transporting personal property,” and “primarily designed to remain within 25 ft of personal property owner” both indicate that there would be other uses.
“Personal property owner is actively monitoring navigation and operation” seems to indicate that a device could operate autonomously or via remote control as long as it was under the auspices of the owner. There are rigorous testing and reporting requirements for autonomous vehicles to use streets in the city of Boston; autonomous vehicles should not be allowed on sidewalks without similar care and attention.
The language “a mobile carrying device has the rights and obligations applicable to a pedestrian” will give more legal protection in a crosswalk to a 90-lb device than to a person using a bike or scooter.

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

Thank you,

Brendan Kearney
Communications Director, WalkBoston

Stacy Thompson
Executive Director, LivableStreets Alliance

Re: Comments on H3073/S2049 An Act relative to micro-mobility and motorized scooters

By WalkMassachusetts | March 28, 2019

March 28, 2019

Joint Committee on Transportation
Joseph A. Boncore, Senate Chair
State House, Room 112
Boston, MA 02133

Joint Committee on Transportation
William Straus, House Chair
State House, Room 134
Boston, MA 02133

Re: Comments on H3073/S2049 An Act relative to micro-mobility and motorized scooters

Dear Chairman Boncore and Chairman Straus,

WalkBoston is Massachusetts’ main pedestrian advocacy organization, working to make walking safer and easier in Massachusetts to encourage better health, a cleaner environment and more vibrant communities. We write to provide the Committee with our comments on H3073/S2049 An Act relative to micro-mobility and motorized scooters.

We understand the need for state legislation to guide the roll out of scooters in Massachusetts and support the efforts of MassDOT, the Metropolitan Area Planning Council (MAPC), and a number of the state’s municipalities to provide a statewide framework for these new mobility devices. We also believe that scooters may positively add to mobility options for Massachusetts’ residents.

At the most fundamental level, we believe that in areas of the Commonwealth where there is more than occasional sidewalk use by pedestrians, motorized scooters should be accommodated on-street or in separated bike/scooter lanes where they will not conflict with people who are walking on the sidewalk.
As reporting is beginning to emerge from cities where scooters have been operating the number of pedestrian injuries attributed to scooters on sidewalks is significant, with 8% of “scooter” injuries in Los Angeles being pedestrians who were hit by scooters or tripped over scooters on sidewalks.
After many years of work to meet the requirements of the federal Americans with Disabilities Act of 1990 (ADA) we are only beginning to approach an accessible sidewalk system. WalkBoston is very concerned that allowing the use of scooters on sidewalks will result in scooters blocking sidewalks and curb ramps. We recommend that municipal regulations require scooters to be locked to appropriate bike racks or corrals, as other communities around the country have started to consider.

Our comments are focused on H3073/S2049 because this is a comprehensive bill that has been drawn up with the active participation of the agencies noted above.

We are pleased that the bill limits scooters to a speed of 15 miles per hour, although this will be very fast if it is happening on a sidewalk where pedestrians are walking at 2-3 miles per hour.
We are pleased that the bill requires scooters to have front and rear lights and turn signals.
As currently drafted the act would allow motorized scooters on all shared use paths operated by MassDOT or the Department of Conservation and Recreation (DCR) including such places as the Southwest Corridor, the Esplanade, the Mass Ave and Longfellow Bridge sidewalks, and the Cape Cod Rail Trail. We do not believe that these heavily used paths that double as linear parks with significant numbers of young children, people with disabilities and seniors should be used by motorized scooters unless they are operated at a significantly lower speed (5 mph).

Thank you for the opportunity to comment on this important piece of transportation safety legislation.

Best regards,

Wendy Landman
Executive Director

Carol Steinberg
WalkBoston Board Member
Wheelchair user and 9-year member of the MA Architectural Access Board

Comments delivered at MBTA Fare Proposal Public Hearing on Feb 27, 2019

By WalkMassachusetts | February 28, 2019

WalkBoston is greatly concerned that the MBTA’s proposal to increase fares will reduce public transit ridership and increase driving, congestion, and greenhouse gas emissions. This is the wrong direction for the Greater Boston area and for Massachusetts as a whole. We need more people riding transit, not fewer, if we are to meet our climate change goals as a Commonwealth.

We are further concerned that the proposed fare increase will disproportionately impact low-income riders, who often lack other means of transportation. Paired with walkable streets and neighborhoods, a reliable, consistent public transportation system is a lifeline for many people. It is an important element of good quality of life, as well as economic and social mobility, for many Greater Boston and Massachusetts residents.

The debate over increasing MBTA fares is a symptom of a much larger problem: how we fund transportation in Massachusetts is broken, and we fail to consider our transportation system as a whole. MBTA riders are asked to pay more time and time again, yet the gas tax has only been increased once since 1991 (in 2013, by just 3 cents). Meanwhile our Regional Transit Authorities continue to struggle and our roads and bridges face significant funding gaps. We need to raise revenue across all travel modes to support the infrastructure needed for all travel modes.

Massachusetts is not short on ideas for increasing transportation funding. This problem has been studied extensively and solutions are within reach. What is lacking is political will. We encourage the MBTA to work with MassDOT and other stakeholders to find new sources of revenue to equitably invest in the 21st-century transportation system we all deserve.

Thank you.

Comments on Arborway Safety Audit Meeting and DCR Parkway Needs Along the Necklace

By WalkMassachusetts | February 7, 2019

February 7th, 2019

Commissioner Leo Roy
Department of Conservation and Recreation
251 Causeway St, 9th Floor
Boston, MA. 02114
Re: Arborway, Jamaica Plain, MA.

Dear Commissioner Roy:

We are writing to express our strong desire to partner with DCR and others to improve
safety for all users on the Arborway section of the Emerald Necklace in the Jamaica Plain
neighborhood for Boston. This area forms part of the larger Emerald Necklace and poses
serious challenges accommodating pedestrians, bicycles and automobiles safely in a
continuous manner along its length.

Over the last several years, DCR planning efforts have started, meetings have been held,
proposals made, but final plans or improvements are not yet planned or realized. We ask
that you re-double your efforts to improve Arborway from Jamaica Pond/Kelley Circle to
the new Casey Arborway. The Conservancy and our partners at Walk Boston and The
Boston Cyclists Union are very concerned with the number of incidents that have taken
place along the Arborway in Jamaica Plain recently. This section of roadway has proven to
be an increasingly dangerous stretch over the last couple of years, and we would like to
draw your attention to what seems to be a growing number of incidents in recent months.
The incidents have ranged in seriousness. Last year, a victim of a crash in 2013 succumbed
to his serious brain injuries and died.

Based on information received from local residents and the Arborway Coalition over the
summer months in 2018 there were:

3 crashes through the fence across from the Arboretum resulting in damage to the fence and
trees.
The pedestrian crossing sign at Murray Circle/Centre Steet /May Street was hit and
knocked over twice, with tire tracks visible on the sidewalk.
A hit and run involving a motorist and bicyclist at Murray Circle.

Based on information gathered from a State Police Report (likely NOT complete) there were
approximately 150 reported crashes on the Arborway from Jan. 5, 2017 to Aug. 8, 2018,
which is an average of over 8 crashes per month.

In the fall of 2018, the Conservancy’s staff, Board of Overseers and others organized walks
through this area of the Arborway. Attendees included Nika Elugardo, new State Representative,
and Jennifer Norwood of DCR. The walks were helpful to see the issues along this section of
parkway (excessive speeds, lack of clear and safe pedestrian and bicycle amenities) and make it
clear that we are seeking a solution that improves safety for all – pedestrians, bicyclists and
automobiles.

We understand that alterations to the Arborway section of the parkways were put on hold until
the new Casey Arborway was completed. The Casey Arborway roadway work is now in place, so
we hope improvements can proceed without delay to the remainder of the Arborway.

We were pleased to recently learn that DCR is doing a comprehensive road safety audit of this
section of parkway and is working with MassDOT to collect all available data. We look forward to
joining an anticipated site walk and seeing a final report in April.

It is our hope that this safety audit will lead to good information, and will lead to a plan to make
improvements. Please let us know how we can support your efforts towards this goal.

Thank you for your attention to this pressing matter.

Sincerely yours,

Karen Mauney-Brodek, President
Emerald Necklace Conservancy

Wendy Landman, Executive Director
WalkBoston

Becca Wolfson, Executive Director
Boston Cyclists Union

Cc: Chris Cook Chief, Environment, Energy, and Open Space; Commissioner, Parks and Recreation;
Erin Gallentine, Director of Open Space, Town of Brookline;
Patrice Kish, Director of Historic Resources, DCR;
Jennifer Norwood, Director of External Affairs and Partnerships, DCR;
Conservancy Board of Directors and Overseers
Nika Elugardo, State Representative
Liz Malia, State Representative
Matt O’Malley, City Councilor

Comment Letter on Paul Dudley White Construction Period Maintenance (02/7/19)

By WalkMassachusetts | February 7, 2019

February 7, 2019

Stephanie Pollack                                             Leo Roy
Secretary of Transportation Commissioner
Commonwealth of Massachusetts Department of Conservation & Recreation
Transportation Building                                   251 Causeway Street
10 Park Plaza 9^th Floor
Boston, MA 02116                                            Boston, MA 02114

Dear Secretary Pollack and Commissioner Roy:

We, the undersigned organizations, applaud MassDOT’s decision to rebuild the interchange of I-90 in Allston by reconstructing the Turnpike in a way that will result in wider riverside parkland and, we anticipate, restored riverbank. In addition to its environmental benefits, this will enhance facilities for the walkers, cyclists, and runners who flock to the area for recreation and commuting. We write to respond to the announcement that construction of the I-90 Intermodal Project will require an extended closure of the Paul Dudley White (PDW) path.

We urge you to develop a plan to retain the path during the construction period. We acknowledge that the project design next steps involve extensive mitigation, that stakeholders will continue to actively participate in stakeholder discussions, and that there is an immediate need to flag concerns regarding the PDW path.

The construction of the I-90 Project cannot and should not require closure of the Paul Dudley White (PDW) path for 8-10 years. The number of people who use the path and rely upon it as a commuter route is simply too large (and growing) to result in PDW users’ diversion to Cambridge. The proposed detour routes through Cambridge are difficult to maneuver and involve unsafe situations where path users will be forced to cross dangerous intersections and cyclists will be directed toward narrow sidewalks causing hazardous conditions for pedestrians sharing the walkway.

Our understanding is that closure of the PDW is an anticipated result of construction in the Throat area. We also understand that other parts of the project site, which are not as confined, offer places where the PDW path can be integrated safely with the highway construction. The law requires that MassDOT implement “all possible planning to minimize harm to the . . . recreation area” during and after construction. To comply, MassDOT and DCR must mitigate construction impacts in the Throat area allowing the PDW path to remain open for as much of the construction period as practicable, preferably on land or, if there is no other option, on a temporary structure in the Charles River.

In the past short temporary boardwalks have been built in the Charles River — for example, to bypass the Bowker interchange reconstruction. Temporary boardwalks have been used safely and effectively in the Indiana Dunes National Lakeshore park in Indiana, Jones Beach State Park in Wantagh, New York, and at beaches in the Cape Cod National Seashore and in Duxbury and Sandwich, Massachusetts.

We urge you to incorporate plans to ensure access to the PDW path on the Boston side of the Charles River as you proceed with the difficult design work in the I-90 Throat area. The provision of atemporary Boston-side walking and biking path during construction is a necessary and legally required project element to mitigate any interruption in access to the permanent PDW path and prevent the safety problems that a Cambridge detour would bring to pedestrians and cyclists. Given the potentially lengthy roadway disruptions, alternative modes of transportation on the PDW will be critical to the Project’s success. We further request that the PDW path construction phase plans be added to the agenda for an upcoming Allston Multimodal Project Task Force meeting.

Thank you very much for your consideration and we look forward to your response.

Wendy Landman, Bob Sloane, WalkBoston
Margaret Van Deusen, Pallavi Mande, Charles River Watershed Association
Laura Jasinski, Harry Mattison, Charles River Conservancy
Staci Rubin, Conservation Law Foundation
Michael Nichols, The Esplanade Association
Galen Mook, Executive Director, MassBike
Becca Wolfson, Boston Cyclists Union
Stacy Thompson, Livable Streets

CC:
City of Boston, Mayor Marty Walsh, Chief of Streets Chris Osgood
City of Cambridge, Mayor Marc McGovern, Transportation Program Manager Bill Deignan
Town of Brookline, Transportation Board Chair Chris Dempsey
FHWA, Division Administrator Jeff McEwen, Assistant Division Administrator Ken Miller
Senator Joseph Boncore
Senator William Brownsberger
Senator Sal DiDomenico
Representative Michael Moran
Representative Kevin Honan
Representative Jay Livingstone
Representative Tommy Vitolo