Category: Comment Letter

Comments on the Environmental Notification form for the second phase of the Clipper City Rail Trail Phase II in Newburyport and Newbury, MA MEPA# 15191

Comments on the Environmental Notification form for the second phase of the Clipper City Rail Trail Phase II in Newburyport and Newbury, MA MEPA# 15191

By |

May 12, 2014

Richard K. Sullivan, Jr. 
Executive Office of Energy and Environmental Affairs
Attn: Alex Strysky
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Environmental Notification form for the second phase of the Clipper City Rail Trail Phase II in Newburyport and Newbury, MA MEPA# 15191

Dear Secretary Sullivan:

WalkBoston has reviewed the Environmental Notification Form for the Clipper City Rail Trail Phase II, which calls for a new multi-purpose trail on a 1.5 mile section of former rail property – the old City Branch line – in the eastern part of the city. Phase II will also extend along a significant portion of the Merrimack River waterfront in the city center. This new trail adds to the existing 1.1 mile rail trail (Phase I) which links the MBTA commuter rail station and Merrimack River not far from the center of the city. A later Phase III will join these two segments in the vicinity of the existing commuter rail station south of the city, but not along the Merrimack River.

Our review leads us to offer these comments:

Design the trail for expansion 
The proposal for Phase II includes an 8-10 foot wide path. The right-of-way for the trail is irregular, as it passes through publicly owned land that includes 19.4 acres. With this space, plans should recognize the possibility that the path will need to be widened if it is successful in drawing users. Many rail trails in Massachusetts are 10-12 feet wide, permitting a 5-6 foot path in each direction. For example, an extension of the Bruce Freeman Trail in Acton will provide a 12-foot trail with 2-foot wide shoulders on both sides to allow space for pedestrians to step aside from other users of the path if they feel the need to let them pass (a possibility if bicycles are passing).

Design the rail trail to include runners 
Rail trails are a success in Massachusetts. Concurrent with the growth in use, new paths need to be carefully designed to serve a wide variety of users. Phase II of the Clipper City Rail Trail appears to be a very desirable facility, and it makes sense to design it to accommodate runners who are frequent users of trails. Runners often prefer a softer surface than that favored by cyclists and walkers; stone dust has frequently been used because it is resilient and provides a comfortable running surface.

Phase II of the Clipper City Rail Trail has significant right-of-way space that would allow more than a basic bicycle and pedestrian path. With space available, a parallel running track should be considered for the Trail. Even if such a running track is a future addition to the facility, space for such a track should be preserved for the future. In a state known around the world for the Boston Marathon and the many sponsored running events, runners should be included, along with the walkers and bicyclists who may be the prime users of the proposed facility.

Connecting Phase I and Phase II in the city center 
Plans for connecting Phase I and Phase II of the Trail along the Merrimack River in the waterfront area of Newburyport are not included in this document. Omitting mention of such a potential connection seems to diminish the potential created by Phase II construction. Phase II, paralleling the Merrimack River, terminates at Custom House Way, at a point that appears to be adjacent to a portion of the existing Waterfront Promenade Park. This open space has a seawall and boardwalk that can extend the walk two to three blocks further west. Admittedly, at the western end of Promenade Park, an off-street right-of-way may be difficult to find. Sidewalks may have to be used to pass along these few blocks, but if completed, this connection between Phase I and Phase II would afford a 2.4 mile loop around many of the older portions of the city.

Thank you for the opportunity to comment on this important project.

Sincerely, 

Robert Sloane 
Senior Planner

WalkBoston Comments on USDOT Highway Safety Performance Measures

WalkBoston Comments on USDOT Highway Safety Performance Measures

By |

May 14, 2014

U.S. Department of Transportation
Docket Operations
M-30, West Building Ground Floor, Room W12-140
1200 New Jersey Avenue SE
Washington, DC 20590

WalkBoston is Massachusetts’ leading pedestrian advocacy organization. We work with urban, suburban and rural communities across the state to improve walking conditions, increase the safety of pedestrians, and encourage people to walk more for transportation, health and recreation. Walking is a critical ingredient of public health, and the capacity of Massachusetts and the United States to get more of our residents walking more will have an enormous impact on the quality of life for Americans, on the health care costs that our country will bear, and on our ability to create sustainable and attractive communities for everyone.

The role of USDOT in walking is vitally important. By setting the ground rules by which states must attend to the safety needs of all roadway users, the Department is declaring the importance of how those roads are designed, operated and maintained. We strongly urge USDOT and FHWA to measure, regulate and demand the safety of pedestrians as part of the country’s transportation system.

WalkBoston is one of the frontline organizations working to make sure that all people in Massachusetts can choose to walk safely in their communities. We work closely with the state’s Departments of Transportation, Public Health and Environment, along with many municipal and grassroots partners. We need the strong support of USDOT as a partner in this effort and a champion for walking safety.

As a member of America Walks we look to our national partner to provide the technical background on USDOT’s rulemaking. As clearly expressed by America Walks, the following improvements are needed in proposed rulemaking on the Highway Safety Improvement Program’s National Performance Management Measures [Docket No. FHWA-2013-0020].

1. States and MPOs must measure the non-motorized users separately from motorized users.

In MAP-21, Congress amended the Highway Safety Improvement Program (HSIP) to clearly support projects, activities, plans, and reports that improve safety for all types of users. In Section 148(a)(8), a road user is defined as a “motorist, passenger, public transportation operator or user, truck driver, bicyclist, motorcyclist, or pedestrian, including a person with disabilities.” Projects included in this program, described in Section 148(a)(4)(B), clearly include a number of changes to the built environment that improve safety for non-motorized users. Congress, in Section 148©(2)(A)(vi), calls for improvement in “the collection of data on non-motorized traffic crashes” and in Section 148(d)(1)(B) requires that states address “motor vehicle crashes that include fatalities or serious injuries to pedestrians and bicyclists”. These changes reflect the growing number of constituents who walk or bicycle as a means of travel and the increasing fatality rate of these modes, even as motorized fatality rates drop. 

Yet, the proposed rule does not require states to measure non-motorized users separately from motorized users. It justifies this decision with two reasons: 1) a lack of data on non-motorized safety and 2) that there are too few non-motorized fatalities and injuries to establish a statistically valid target.

We agree that currently available data sources are imperfect or incomplete, but that should not preclude us from establishing and measuring goals to improve non-motorized safety. The Fatality Analysis Reporting System (FARS) identifies the number and location of both motorized and non-motorized fatalities. FARS is a valid and well-supported source that can easily inform non-motorized safety improvement measures. While injury data is still often unreliable—for all travelers—the proposed rule’s recommendation to link roadway crash data with that from hospitals and emergency responders will provide a more accurate data source than currently available. This data shortcoming does not prevent the establishment of motorized injury reduction targets and should not stop the creation of non-motorized targets either. Several states and numerous cities already participate in a voluntary activity to track travel by foot and bicycle. We believe that the establishment of a separate performance measure for non-motorized users will create a clear incentive for the improved data collection and analysis intended by Congress in MAP-21.

In 2012, pedestrians and bicyclists represented 16 percent of all traffic fatalities – up from 12 percent just a few years prior. In three out of five states, non-motorized crash victims already make up more than 10 percent of fatalities, and in some states, they represent 20 percent or more. This is a significant number of deaths. While the residents of some states are fortunate to have low fatality rates, they should work to bring that number to zero—and keep it there. Statistical validity is an unnecessary qualifier.

Indeed, despite the data concerns, some states already have established specific non-motorized transportation safety targets in statewide bike and/or pedestrian plans and in their Strategic Highway Safety Plans. We urge USDOT to revise the rule to measure progress on non-motorized safety as an independent target from motorized safety.

2. Base success on actual targets set by state DOTs and MPOs, not historical trends.

MAP-21’s first national goal is safety, as demonstrated by a significant reduction in traffic fatalities and serious injuries on all public roads. Over the last ten years for which the National Highway Traffic Safety Administration has released data, more than 383,000 people died on  our nation’s roads. Fatalities dropped from 42,868 in 2003 to 33,560 in 2012. It is not unreasonable to charge ourselves with further reducing that number—and to bring the incidence of serious injuries down with it.

States and MPOs currently set real targets, based not on trends but on a common understanding that they can act to protect the traveling public. USDOT should evaluate states and MPOs on their progress meeting their targets. If they meet the threshold established by USDOT, states and MPOs would not need any additional analysis on progress. Those agencies that fail to meet that threshold should not be allowed a flexible use of Highway Safety Improvement Program funding, instead those monies should be spent only on safety improvement projects identified in adopted State Highway Strategic Plans. 

3. Charge States and MPOs with meeting all required safety targets but recognize those meeting three-quarters of the safety targets established in MAP-21 and half of any additional, voluntary targets as making significant progress. (Section 490.211 subparagraph (3).

MAP-21 provided clear language and intent of Congress as presented by the Declaration of Policy (23 U.S. Code § 150 (a)). Congress did not provide the opportunity for States to progress on just half of their legislatively mandated measures. In the proposed rulemaking, U.S. DOT created a wholly different system of statistical analysis that does not consider the actual targets that were set by the State or MPO.

States and MPOs should strive for 100 percent success on the safety performance measures established in U.S. law. U.S. DOT should provide some flexibility by recognizing States and MPOs that meet 75 percent of the required measures as having made “significant progress” toward that endpoint. States or MPOs that voluntarily create additional safety measures should be measured against a 50 percent threshold for those targets. By doing so, U.S. DOT balances the extra efforts of such agencies while still holding them accountable to their goals.

We recommend U.S. DOT follow a simplified process for analyzing progress each calendar year:

• A State or MPO that meets all four required targets and at least half of any additional, voluntary targets is not subject to further analysis.

• A State or MPO that achieves three of the four required targets and at least half of additional targets will have made “significant progress” and is not subject to further analysis.

• A State or MPO that fails to achieve three or more of its required targets is required to use its full allocation of Highway Safety Improvement Program funding only on safety projects identified in the State Strategic Highway Safety Plan.

• A State or MPO that fails to meet the same required safety target in successive years cannot be considered to have made “significant progress” and should be required to spend Highway Safety Improvement Program funding only on projects identified in the State Strategic Highway Safety Plan.

• A State or MPO that fails to achieve at least half of its additional voluntary safety targets in successive years should be required to spend at least half of its Highway Safety Improvement Program only on safety projects identified in the State Strategic Highway Safety Plan.

Conclusion 
Safety guides transportation agencies at all levels of governance. A strong, clear safety performance measurement system will align our transportation agencies’ intent with actual outcomes and performance by focusing funding and attention on key issues such as speeding, distracting driving, drinking and driving, and best practices in multimodal roadway planning and design. With leadership from Congress and USDOT through the HSIP’s National Performance Management Measures, we can ensure significant safety improvements in the coming years.

Thank you for the opportunity to comment on the proposed rulemaking.

Wendy Landman 
Executive Director 

CC: 
Senator Elizabeth Warren 
Senator Edward Markey
Representative Richard Neal, 1st District
Representative Jim McGovern, 2nd District
Representative Niki Tsongas, 3rd District
Representative Joe Kennedy, 4th District
Representative Katherine Clark, 5th District
Representative John Tierney, 6th District
Representative Mike Capuano, 7th District
Representative Stephen Lynch, 8th District
Representative Bill Keating, 9th District
Massachusetts Secretary of Transportation Richard Davey
Massachusetts Commissioner of Public Health Cheryl Bartlett
Boston Mayor Martin Walsh

Beacon Street Multimodal Improvements Comment Letter-Somerville, MA

Beacon Street Multimodal Improvements Comment Letter-Somerville, MA

By |

May 13, 2014

Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs
Attn: Alex Strysky
100 Cambridge St., Suite 900
Boston MA 02114

Mark Kolonoski
MassDOT Highway Division
Environmental Services Section
10 Park Plaza, Room 4260
Boston, MA 02116

RE: Comments on the Environmental Notification Form for the Beacon Street Multimodal Improvements and Streetscape Enhancement in Somerville, MA

Dear Secretary Sullivan and Mr. Kolonoski:

The Beacon Street project area extends from the bridge abutment at Oxford Street to Dickinson Street, a distance of approximately 1.1 miles. The project is intended to enhance pedestrian and bicycle movements with improved streetscape, wider sidewalks, a new cycle track/bicycle lanes, and new ADA compliant curb ramps. The project goal is to enhance the multimodal connectivity of the Beacon Street Corridor.

We have reviewed this project and offer the following comments:

1. Updated and continuous sidewalks on Beacon Street
The program for complete streets along Beacon Street will result in new cycle tracks and a significant reconstruction of both the street and the sidewalk. Sidewalks are to be updated and rebuilt to correct current deficiencies, including substandard slopes and lack of ramps at intersections. A sidewalk will be added to the south side of Beacon Street in a location where no sidewalk now exists. Adherence to this plan is essential for the safety and convenience of all users of the sidewalk.

The proposed sidewalks will replace the existing 10’-11’ wide sidewalks with new ones of substantially the same width. Retention of this dimension as a minimum is extremely important because some space within the sidewalk will accommodate other uses, such as trees. In only one portion of Beacon Street, where there are space constraints due to an existing stonewall, will the 10’-11’ width be precluded; we note
that no trees are planned for the sidewalk in this section.

2. Cycle tracks and bike lanes
Cycle tracks are proposed between Oxford Street and Museum Street, bike lanes between Museum Street and Park/Scott Streets, cycle tracks between Park/Scott Streets and Washington Street and bike lanes between Washington Street and the Cambridge City line. On the north side of the street, the alignments of the cycle tracks and bike lanes are end-to-end, resulting in a virtually straight path for the full length of
the project.

On the south side of the street the cycle tracks and bike lanes do not quite line up. The transitions between cycle tracks and bike lanes at the intersection of Beacon Street/Museum Street and Park Street/Washington Street are angled to accommodate the needed connections between cycle tracks and bike lanes. These intersections have crosswalks where pedestrians will cross near the bike routes. Since separate traffic signals for bicycles are not included in the project, WalkBoston is concerned that walkers may not be aware that bicycles are approaching at these intersections and need to be especially careful because these diversions might distract the cyclists or the
motorists. We request that special signage and/or pavement markings be provided to alert walkers, bicyclists and drivers of these shifts in alignment and the need to be aware of movements by others.

3. Separation of cycle tracks and sidewalks
In several locations, the proposed cycle tracks are immediately adjacent and at the same grade as the sidewalk. In effect the cycle track will be located on an extension of the sidewalk. A pronounced and clear separation between bicyclists and walkers is needed to deter cyclists from using the sidewalk to bypass slower moving bikes. The
starting and stopping of cycle tracks and bike lanes may be confusing and lead to cyclists using the sidewalks to avoid merging into traffic or worrying about people opening car doors directly in front of them.

Since all 208 of the street trees included this project are to be planted within the width of the sidewalk, we assume that they will help to separate the cycle track from walkers. Other street furniture such as the existing utility and lighting poles, or new benches, trash containers, bollards or signs might also help. The precise location of each element should be carefully considered, as they have the potential to interfere with pedestrian or bicycle movements.

4. Placement of trees
Although the sidewalks are 10 feet wide in nearly all locations along Beacon Street, some of that width – perhaps up to 5 feet – will be lost due to the planting of 208 trees directly in the sidewalk. All of the proposed new trees should be placed in long narrow tree pits (we have seen tree pits that are 2’ wide by 6’-8’ long). More typical 4-foot square tree pits that intrude into the sidewalk should not be used. Irrespective of the shape of the tree pit, tree grates and or special permeable but sturdy filler (similar to that used in some South End locations) should be explored. This is important for the safety of walkers, as is the long-term maintenance of the tree pits so that they do not pose tripping hazards for walkers or for the visually-impaired.

5. Traffic signals at crosswalks and mid-block
New traffic signal equipment and signal timing at the intersections of Beacon Street with Park/Scott and Washington Streets are planned. In addition, two High-Intensity Activated crossWalK (HAWK) pedestrian signals on mast arms are planned for pedestrian crossings at the Sacramento Street intersection and at the Buckingham/Cooney intersection. The project thus appears to have signals of some sort at intervals of about ¼ mile; however, in the portion of Beacon Street between Sacramento Street and the rail overpass at Somerville Avenue, the intersections with Oxford and Prentiss Streets have no traffic signals. With no signals to slow traffic these mid-block crossings may be difficult for pedestrians. Signage or other warnings may be essential to inform drivers and cyclists of the crosswalks.

6. Crosswalk paving
The proposed use of concrete pavers at crosswalks has been cited by one of our members as a hazard for nearly all walkers, and we agree. For all crosswalks on Beacon Street, the customary white reflective thermoplastic strips should be used. Pavers have low visibility and are uneven, making it harder for wheelchairs, seniors, and people pushing strollers or grocery carts.

7. Pedestrian signal phasing
At existing signal locations the exclusive pedestrian phase will be replaced with concurrent pedestrian phasing. For all new signals, a leading pedestrian interval (LPI) is proposed to allow pedestrians to enter the crosswalk before vehicles approaching the intersection have a green signal indication. It will be important to coordinate the LPI at each signalized intersection with any preferential treatment given to bicycles at the same location, to avoid potential conflicts.

8. Signage
There is a need for sidewalk and cycle track signs that make it clear to walkers, bicyclists and drivers how the cycle tracks function. In particular, since all the street’s users will be unfamiliar with cycle tracks it will be important to let pedestrians know what to expect in bicycle movements adjacent to them. Signs should advise bicycles to stay within the cycle tracks and avoid using the sidewalks. Signs should advise walkers of approaching bicycle traffic,places to wait before crossing the street, and to not walk in the cycle tracks. Specific notice should be given to cyclists and pedestrians of potential conflicts at intersections, where turning bicycles, vehicles and pedestrians present many different movements.

9. Lighting
New street lighting has not been proposed, and cyclists may be ‘invisible’ to walkers and drivers. The City should explore the need for additional lighting, especially at intersections where so many different movements will be taking place. In addition, as part of the introduction of the cycle track, the City should explore the opportunity to market and enforce state laws requiring bicycles to carry white front lights on bicycles visible that are visible from 500 feet. WalkBoston has received comments from a number of our older members that they find it impossible to see bicyclists approaching at night if they do not use head lights, and with the addition of a sidewalk level cycle track they are very nervous about crossing the track at intersections.

10. Driveways
A great number of private driveways will be accommodated with this design, with each rebuilt to cross both sidewalk and bicycle facilities. The north side of the street has 43 driveways and the south side has 30. Most of the driveways are narrow, and will involve drivers who will back out to reach Beacon Street. Drivers backing vehicles into the street may have obstructions that limit abilities to see approaching walkers, runners or cyclists.

11. Speed control
Speeds on local streets that are primarily residential such as Beacon Street should be strictly regulated. The current 30-mph limit should not be raised. It should be made lower with advisory signs if possible. Reminder signs should be posted at intervals along the route to warn drivers not to go faster.

Thank you for the opportunity to comment on this project. Please feel free to contact us if you should have questions.

Sincerely,

Wendy Landman
Executive Director

Robert Sloane
Senior Planner

Comments on Arborway Crosswalk Improvements presentation

Comments on Arborway Crosswalk Improvements presentation

By |

May 15, 2014

Commissioner Jack Murray
Attn: Office of Public Outreach
Department of Conservation and Recreation
251 Causeway Street, Suite 600
Boston, MA 02114

Re: Arborway Crossing

Dear Commissioner Murray:

WalkBoston attended the May 6th public meeting and has reviewed DCR’s Arborway Crosswalk Improvements presentation.

First, we are pleased that DCR has responded to community concerns regarding the crosswalk’s unsafe existing conditions. The research by Toole Design Group seems thorough and we support their analysis. I personally live just a few blocks from the Arborway crosswalk. I use the crosswalk regularly to visit the Arnold Arboretum and I drive on the Upper Arborway. I see firsthand the risks of the current configuration.

We agree with some of Toole’s recommendations:
‐ Relocate the fence to improve sight lines
‐ Upgrade WALK signal (on main Arborway) to a countdown signal
‐ Improve signage and pavement markings

However, we do not support the “tiered” approach as presented. We believe that a geometric modification must be made to ensure that vehicles slow down at the crosswalk. Anything less than this will not adequately protect park visitors from driver error (or their own error). Geometric modifications should be a top priority, not postponed till the 3rd tier. This location needs either:
‐ Installation of a Raised Crosswalk in combination with a curb extension, or
‐ Installation of a Chicane with a curb extension on the west side of the Upper Arborway.

The changes that the Town of Brookline made to Pond Avenue along Olmsted Park are a good model for raised crosswalks. Pond Avenue formerly had similarly hazardous crosswalks, somewhat greater traffic volumes, and chronic speeding. The Town installed 3 or 4 raised crosswalks between Route 9 and the Chestnut Street rotary; these force vehicles to really slow down at the crosswalks.

In addition we would like to see:
‐ Construction of a larger queuing area where pedestrians and bikes can wait on the median between the main Arborway and the Upper Arborway
‐ Installation of some physical barrier such as bollards to clearly mark the edge between the waiting area and the Upper Arborway roadway.

With changes to roadway geometry the installation of Rectangular Rapid Flash Beacons — while somewhat effective — would probably be unnecessary. (In the absence of geometric modifications, the RRFBs would be a necessity.)

Thank you for the opportunity to comment on Arborway crosswalk safety improvements. Please feel free to contact WalkBoston with any questions. We would be happy to meet with you about our recommendations.

Sincerely,
Don Eunson
Former WalkBoston Board Member and Jamaica Plain resident

cc: Patrice Kish, DCR
Julie Crockford, Emerald Necklace Conservancy
Jessica Mortell, EIT, Toole Design Group

Comments on HSIP National Performance Management Measures

Comments on HSIP National Performance Management Measures

By |

May 14, 2014

U.S. Department of Transportation

Docket Operations

M-30, West Building Ground Floor, Room W12-140

1200 New Jersey Avenue SE

Washington, DC 20590

WalkBoston is Massachusetts’ leading pedestrian advocacy organization. We work with urban, suburban and rural communities across the state to improve walking conditions, increase the safety of pedestrians, and encourage people to walk more for transportation, health and recreation. Walking is a critical ingredient of public health, and the capacity of Massachusetts and the United States to get more of our residents walking more will have an enormous impact on the quality of life for Americans, on the health care costs that our country will bear, and on our ability to create sustainable and attractive communities for everyone.

The role of USDOT in walking is vitally important. By setting the ground rules by which states must attend to the safety needs of all roadway users, the Department is declaring the importance of how those roads are designed, operated and maintained. We strongly urge USDOT and FHWA to measure, regulate and demand the safety of pedestrians as part of the country’s transportation system.

WalkBoston is one of the frontline organizations working to make sure that all people in Massachusetts can choose to walk safely in their communities. We work closely with the state’s Departments of Transportation, Public Health and Environment, along with many municipal and grassroots partners. We need the strong support of USDOT as a partner in this effort and a champion for walking safety.

As a member of America Walks we look to our national partner to provide the technical background on USDOT’s rulemaking. As clearly expressed by America Walks, the following improvements are needed in proposed rulemaking on the Highway Safety Improvement Program’s National Performance Management Measures [Docket No. FHWA-2013-0020].

  1. States and MPOs must measure the non-motorized users separately from motorized users.

In MAP-21, Congress amended the Highway Safety Improvement Program (HSIP) to clearly support projects, activities, plans, and reports that improve safety for all types of users. In Section 148(a)(8), a road user is defined as a “motorist, passenger, public transportation operator or user, truck driver, bicyclist, motorcyclist, or pedestrian, including a person with disabilities.” Projects included in this program, described in Section 148(a)(4)(B), clearly include a number of changes to the built environment that improve safety for non-motorized users. Congress, in Section 148(c)(2)(A)(vi), calls for improvement in “the collection of data on non-motorized traffic crashes” and in Section 148(d)(1)(B) requires that states address “motor vehicle crashes that include fatalities or serious injuries to pedestrians and bicyclists”. These changes reflect the growing number of constituents who walk or bicycle as a means of travel and the increasing fatality rate of these modes, even as motorized fatality rates drop.

Yet, the proposed rule does not require states to measure non-motorized users separately from motorized users. It justifies this decision with two reasons: 1) a lack of data on non-motorized safety and 2) that there are too few non-motorized fatalities and injuries to establish a statistically valid target.

We agree that currently available data sources are imperfect or incomplete, but that should not preclude us from establishing and measuring goals to improve non-motorized safety.The Fatality Analysis Reporting System (FARS) identifies the number and location of both motorized and non-motorized fatalities. FARS is a valid and well-supported source that can easily inform non-motorized safety improvement measures. While injury data is still often unreliable—for all travelers—the proposed rule’s recommendation to link roadway crash data with that from hospitals and emergency responders will provide a more accurate data source than currently available. This data shortcoming does not prevent the establishment of motorized injury reduction targets and should not stop the creation of non-motorized targets either. Several states and numerous cities already participate in a voluntary activity to track travel by foot and bicycle. We believe that the establishment of a separate performance measure for non-motorized users will create a clear incentive for the improved data collection and analysis intended by Congress in MAP-21.

In 2012, pedestrians and bicyclists represented 16 percent of all traffic fatalities – up from 12 percent just a few years prior. In three out of five states, non-motorized crash victims already make up more than 10 percent of fatalities, and in some states, they represent 20 percent or more. This is a significant number of deaths. While the residents of some states are fortunate to have low fatality rates, they should work to bring that number to zero—and keep it there. Statistical validity is an unnecessary qualifier.

Indeed, despite the data concerns, some states already have established specific non-motorized transportation safety targets in statewide bike and/or pedestrian plans and in their Strategic Highway Safety Plans. We urge USDOT to revise the rule to measure progress on non-motorized safety as an independent target from motorized safety.

  1. Base success on actual targets set by state DOTs and MPOs, not historical trends.

MAP-21’s first national goal is safety, as demonstrated by a significant reduction in traffic fatalities and serious injuries on all public roads. Over the last ten years for which the National Highway Traffic Safety Administration has released data, more than 383,000 people died on our nation’s roads. Fatalities dropped from 42,868 in 2003 to 33,560 in 2012. It is not unreasonable to charge ourselves with further reducing that number—and to bring the incidence of serious injuries down with it.

States and MPOs currently set real targets, based not on trends but on a common understanding that they can act to protect the traveling public. USDOT should evaluate states and MPOs on their progress meeting their targets. If they meet the threshold established by USDOT, states and MPOs would not need any additional analysis on progress. Those agencies that fail to meet that threshold should not be allowed a flexible use of Highway Safety Improvement Program funding, instead those monies should be spent only on safety improvement projects identified in adopted State Highway Strategic Plans.

  1. Charge States and MPOs with meeting all required safety targets but recognize those meeting three-quarters of the safety targets established in MAP-21 and half of any addi-tional, voluntary targets as making significant progress. (Section 490.211 subparagraph (3).

MAP-21 provided clear language and intent of Congress as presented by the Declaration of Policy (23 U.S. Code § 150 (a)). Congress did not provide the opportunity for States to progress on just half of their legislatively mandated measures. In the proposed rulemaking, U.S. DOT created a wholly different system of statistical analysis that does not consider the actual targets that were set by the State or MPO.

States and MPOs should strive for 100 percent success on the safety performance measures established in U.S. law. U.S. DOT should provide some flexibility by recognizing States and MPOs that meet 75 percent of the required measures as having made “significant progress” toward that endpoint. States or MPOs that voluntarily create additional safety measures should be measured against a 50 percent threshold for those targets. By doing so, U.S. DOT balances the extra efforts of such agencies while still holding them accountable to their goals.

We recommend U.S. DOT follow a simplified process for analyzing progress each calendar year:

  • A State or MPO that meets all four required targets and at least half of any additional, voluntary targets is not subject to further analysis.
  • A State or MPO that achieves three of the four required targets and at least half of additional targets will have made “significant progress” and is not subject to further analysis.
  • A State or MPO that fails to achieve three or more of its required targets is required to use its full allocation of Highway Safety Improvement Program funding only on safety projects identified in the State Strategic Highway Safety Plan.
  • A State or MPO that fails to meet the same required safety target in successive years cannot be considered to have made “significant progress” and should be required to spend Highway Safety Improvement Program funding only on projects identified in the State Strategic Highway Safety Plan.
  • A State or MPO that fails to achieve at least half of its additional voluntary safety targets in successive years should be required to spend at least half of its Highway Safety Improvement Program only on safety projects identified in the State Strategic Highway Safety Plan.

Conclusion

Safety guides transportation agencies at all levels of governance. A strong, clear safety performance measurement system will align our transportation agencies’ intent with actual outcomes and performance by focusing funding and attention on key issues such as speeding, distracting driving, drinking and driving, and best practices in multimodal roadway planning and design. With leadership from Congress and USDOT through the HSIP’s National Performance Management Measures, we can ensure significant safety improvements in the coming years.

Thank you for the opportunity to comment on the proposed rulemaking.

Wendy Landman

Executive Director