Category: Comment Letter

MA Vision Zero Coalition comments on New Car Assessment Program

MA Vision Zero Coalition comments on New Car Assessment Program

Submit your own comments to NHTSA about the New Car Assessment Program by June 8th using this simple feedback form created by America Walks.

Friday, May 20th, 2022

As members of the Massachusetts Vision Zero Coalition, we are writing to provide comments on the updates to the New Car Assessment Program. 

The Massachusetts Vision Zero Coalition is composed of transportation advocacy organizations, community-based groups, and individuals representing communities across the state who are dedicated to improving traffic safety in Massachusetts. 

The executive summary of the report shares the following data: “…a statistical projection of traffic fatalities for the first half of 2021 shows that an estimated 20,160 people died in motor vehicle traffic crashes—the highest number of fatalities during the first half of the year since 2006, and the highest half-year percentage increase in the history of data recorded by the Fatality Analysis Reporting System (FARS).[3] In addition, the projected 11,225 fatalities during the second quarter of 2021 represents the highest second quarter fatalities since 1990, and the highest quarterly percentage change (+23.1 percent) in FARS data recorded history”. 

The role that cars themselves play in these crashes cannot be ignored. For many many years, vehicles have been continually designed to improve safety for those inside the vehicle, to the detriment of those outside the vehicle, such as  vulnerable road users like people on foot and on bike. We appreciate that the National Highway Traffic Safety Administration (NHTSA) is taking the safety of those outside of the vehicle into consideration in the adjustment of the New Car Assessment Program (NCAP) safety ratings and the requirement for a 10 year roadmap for the future of NCAP. The NCAP is both a way to educate the public on the safety of new cars and an opportunity to encourage car manufacturers to make the safest products possible. Though this update is a step in the right direction, we believe that there are additional things that NHTSA should consider to even more greatly improve the efficacy of the safety rating program. 

US DOT recently released the first ever National Roadway Safety Strategy, which  included the NCAP update as one of the first concrete steps to address the increase in fatalities on America’s roadways through a safe system approach. Yet despite the National Roadway Safety Strategy stating “Under the Safe System Approach, efforts to make our roads safer should affirmatively improve equity outcomes,” NHTSA’s plan for both this update of the NCAP and its 10 year plan fail to adequately consider vulnerable road users other than people walking, people with disabilities, or Indigenous, Black, and Hispanic people who are disproportionately represented in traffic fatalities and serious injuries. We ask NHTSA to take our following comments into consideration to improve this once in a decade opportunity to address the NCAP.

Vehicle size, height, & weight:

Increasing vehicle size has been continuously linked to fatal pedestrian and bicyclist crashes across the country. A recent study from the Insurance Institute of Highway Safety demonstrated that drivers of larger vehicles like SUVs, vans, and trucks are more likely to hit pedestrians while making right turns than drivers of other vehicles. This suggests issues of visibility and larger blindspots. This is especially concerning given the additional danger that the size, height, and weight of larger vehicles causes to vulnerable road users. Direct vision, visibility, and blindspots/zones for vehicles should be rated as part of NCAP. Europe and other countries have had a direct vision standard for passenger vehicles (cars, pickup trucks, and SUVs) since 2009, and are expanding this standard to newly-built trucks as well. This blind zone measurement tool demonstrates just what the blind spots are for different vehicles, and shows, for example, that a driver of a Ford F-150 truck has a blind spot in front of the vehicle so deep that eight standing elementary school children lined up from the bumper of the vehicle would be invisible

Human-Machine Interface (HMI) and In-vehicle Infotainment System (IVIS):

This should prioritize ease of use and minimize distraction, including less reliance on touch screens and more buttons and dials for basic vehicle functions (like climate control and radio). There should be restrictions on screens built into vehicles (maximum size limit, for instance). Any vehicle with a screen that does not lock when the vehicle is in motion should have a lower safety rating. 

Intelligent speed assistance (ISA):

NHTSA should take Intelligent Speed Assistance into consideration for NCAP. The EU’s European Transport Safety Council found a safety benefit in using these technologies and the General Safety Regulation made an overridable version of ISA mandatory in 2019. They expect ISA to result in a 30% reduction in collisions, and 20% reduction in deaths.

Advanced driver assistance systems (ADAS): 

The inclusion of additional ADAS, including pedestrian automated emergency braking, lane keeping support, and blind spot detection and intervention, is encouraging as these all aim to protect those outside the vehicle. However these ADAS are not without issues and limitations, which we outline below. 

The inclusion of Pedestrian Automatic Emergency Braking (PAEB) systems does not go far enough to truly consider the safety of vulnerable road users. The Bipartisan Infrastructure Law defines vulnerable road users as pedestrians, bicyclists, other cyclists or persons using a personal conveyance as defined by the American National Standards /Manual on Classification of Motor Vehicle Traffic Crashes. This definition includes people using personal conveyances, motorized and non motorized such as wheelchairs and scooters used by people with disabilities, and multiple micro mobility devices. In addition to neglecting all kinds of vulnerable road users beyond pedestrians, the sensors used for PAEB have been proven to not work at night, and concerningly, are not as accurate in sensing people with darker skinned, raising serious equity and safety concerns. A 2019 Study by the Georgia Institute of Technology found that Automated Vehicles do not identify darker skin as well as they identify lighter skin. The study concludes, in part, that more data and research is necessary. Additionally, these sensors are not accurate at detecting people riding bikes, an important feature that the European Union will be including in their standards. 

The Lane Keeping Support (LKS)  systems keep vehicles centered in the lane, even when drivers need to shift to make room for a cyclist who is passing and may not be in a designated lane. This technology should be tested for how it impacts passing people on bikes at a safe distance. 

The blind spot detection and blind spot intervention systems must detect people in wheelchairs, bicyclists, and scooter riders as well as pedestrians.

The ADAS systems NHTSA is now testing are very likely to be the building blocks for more automated vehicles. As NHTSA moves forward with testing of Advanced Driver Assistance Systems it must include tests of different races, ethnicities, and genders, as well as people using wheelchairs and other common mobility devices. Otherwise the outcome of these tests risk increasing the safety inequities in our transportation system.

Testing crash avoidance technology on its ability to detect and respond to vulnerable road users, especially those with darker skin, could avoid future disparities in vulnerable road user crashes and fatalities by encouraging car manufactures to test for people of all races and ethnicities with ADAS now. Vehicles that lack ADAS features that effectively protect people outside vehicles should not receive 5-star ratings.

NCAP Roadmap:

In the 10 year NCAP roadmap outlined in the request for comments, NHTSA stated it would release a plan for testing for crashworthiness—the damage done to a person in the event of crash- of hoods and bumpers—this year. When testing for crashworthiness of pedestrians and vulnerable road users, NHTSA should be required to also use women-specific test mannequins, as opposed to solely using male mannequins.  NHTSA’s own research has shown that women are 17 percent more likely to die and 73 percent more likely to be severely injured in car crashes than men. Testing with women-specific test mannequins will help determine if vulnerable road users experience similar gender disparities, and help car manufacturers avoid that outcome.

The Bipartisan Infrastructure Law also requires NHTSA to consider the benefits of being consistent with other rating systems both within the United States and internationally. The EuroNCAP has been testing for cyclists since 2018, the Australasian New Car Assessment Program (ANCAP) tests for cyclists, as does the Insurance Institute for Highway Safety (IIHS) in the US. NHTSA’s ten year plan does not include testing for cyclists until the 2025-2031 timeframe, showing the US will likely be a decade behind other countries. 

Overall, it is crucial that new vehicles be strictly measured against the NCAP rating system in order for the system to be an effective consumer resource tool and make vulnerable populations safer on our streets. Data suggests that Americans keep their cars for nearly 12 years, meaning  vehicles built today will be on the road for at least a decade, if not longer. Any delay to including additional important changes to the NCAP means a generation of vehicles without these safety measures. 

We appreciate the opportunity to provide comments on the NCAP, and encourage NHTSA to incorporate our suggestions. Thank you for your time and consideration. 

Sincerely, 

The MA Vision Zero Coalition

NCAP Comment Letter – MA Vision Zero Coalition (PDF)
all footnote references included in PDF document

WalkBoston Comments on Stanhope Hotel PNF

WalkBoston Comments on Stanhope Hotel PNF

May 23, 2022
Quinn Valcich
Boston Planning & Development Agency

RE: WalkBoston Comments on Stanhope Hotel PNF

Dear Quinn:

WalkBoston is Massachusetts’ leading walking advocacy organization working to make Massachusetts a safer, more accessible and more attractive place to walk. 

Slide 28 of the presentation dated May 5, 2022 shares the possibility of a “Seasonal Road Closure” for the section of Stanhope Street between the project site and Frieda Garcia Park. Rather than creating a temporary/seasonal closure at this location, we believe that this section of Stanhope Street should be made into a permanent pedestrian-only area as part of this hotel development project. The people-focused space could have a flush curb and sturdy, attractive bollards at each end for better ADA accessibility and protection from vehicle traffic. 

A temporary outdoor pedestrian area was already well received and proven to be a success at this location last summer. We highly recommend that the pedestrian plaza should move beyond the pilot phase into construction as part of the larger Stanhope hotel project. This high quality pedestrian plaza and increased pedestrian traffic would help encourage the city to create a safer crosswalk connection across Clarendon Street to Back Bay Station in the longer term.

Thank you for the opportunity to comment. 

Brendan Kearney 

Deputy Director, WalkBoston

Transportation Advocates South Boston Seaport Strategic Transit Plan Comments

Transportation Advocates South Boston Seaport Strategic Transit Plan Comments

April 1, 2022
Jascha Franklin-Hodge
Boston Chief of Streets

Jim Fitzgerald
BPDA, Interim Deputy Director of Transportation & Infrastructure Planning

Re:  South Boston Seaport Strategic Transit Plan

Dear Jascha and Jim:

Our collective organizations offer joint comments on the South Boston Seaport Strategic Transit Plan. Our comments build on the many verbal and written comments we’ve offered over the last few years, both about this plan, and specific projects within the project area. 

While our organizations are eager to see the City tackle the very significant transit needs of this burgeoning part of the City, we continue to worry that this plan lacks the level of City leadership and cohesive vision needed to allow the neighborhood’s residents, businesses and workers to thrive in the years ahead. We would be pleased to meet with you to discuss our comments and our thoughts about how the project could be more effectively advanced.

Our specific concerns are outlined below: 

Coordination + Cohesion: It remains unclear what the big picture goal and overall time frame is for the plan. As presented at the most recent public meeting, the “plan” was offered mostly as a laundry list of current and potent projects and lacked details about the timeline for implementation. It also lacked an appropriate level of coordination with the bike plan and offered no clear plan for improving accessibility for the area. Any successful transit plan must take these interconnected needs into account. 

  • As a first step, we recommend  putting  all of the recommendations into one description and map color coded by timing of implementation (or perhaps overlays by year). The public needs to understand what is happening when and where.
    • A tremendous amount of development is in various stages of planning and permitting, each of which is documenting their anticipated transit, walking, biking, parking and delivery operations. Please provide a consolidated look at all of these proposals and then describe how the plan for transit, sidewalks, bike lanes and roadways can accommodate the anticipated number of people and vehicles. 
    • Distinguish between the projects for which designs and funding are known (with some degree of certainty) and those which are still only ideas.
    • Identify which entity (or entities) will be responsible for paying for, leading on designs and decision-making, and implementing the projects.
    • Multi-agency complications exist on the roads in the neighborhood as well as in transit operations. Please clarify the ownership of the roads among MassDOT, MassPort and City BTD & BPDA.

Much is still unknown or unclear about the actual transit components of this transit plan. While there are proposed high level connections, there is very little detail about how those connections will be achieved. 

Better bus connections are needed: (1) to/from North Station – and not just connecting to South station; (2) along Summer Street; (3) A Street; (4) Silver Line improvements (5) D Street service to Nubian Square (6) Express bus route changes. In order to provide clarity about what this plan will achieve to improve transit, we recommend: 

  • Including information about the schedules of future service – we understand that precise information is not possible, but a vague description of “increased” service is not adequate.
  • Provide information about where funding will come from for both capital and operational investment
  • Provide a description of the current overall capacity of bus service for the district and what the future capacity goals are.
  • Distinguish between public (MBTA) and private shuttle service. Describe how private shuttles are being considered in the process and whether these services will be opened to the public.
  • Provide details about where buses will layover. Should there be a central point they all serve? Convention Center and Silver Line Way are the only remaining locations owned by the State with sufficient land area. 
  • Outline how this process interacts and is coordinated with the MBTA Bus Network Redesign process. 

MBTA Station improvements are critical to the plan

  • Improve bus circulation around Broadway station with vastly improved pedestrian crossings at West Broadway.
  • Build a new headhouse at Broadway Station to get last mile access from the northern side of West Broadway

Accessibility for people with disabilities must be definitively addressed, especially from South Station to A Street (via Congress Street is not an acceptable answer) and Broadway to the whole district.

  • Schedule a meeting with advocates and Boston Disabilities Commission in Spring 2022.
  • Focus on the network and connectivity, not just piecemeal, but rather a full concept of developed routes to serve as many needs as possible.

This plan must also compliment and contribute to better and safer bike conditions, especially on  Summer Street, Congress Street and  A Street.

  • Clarify the intended network and the timing of each piece of the network.
  • Clarify the goals, location and design of the South Bay Harbor Trail, including a discussion of the proposed width of the trail and whether it will be adequate to serve people walking and biking as a commuter route.
  • Prioritize separated bike lanes because bikes must be a core piece of the transportation system. They must be built into the network not just planned on a development-by-development basis.
  • Additionally, we want to see robust bike parking being considered as critical bike infrastructure – not only indoor bike rooms and bike parking that is accessible to residents and workers in new buildings, but on-street (or street-accessible), high-capacity bike parking, and want to ensure it is accounted for with all transportation planning in the area.

Make a final determination that there will be no vehicles, other than emergency access, on Northern Avenue Bridge. There has not been a public meeting about the Northern Avenue Bridge project since April of 2020. At that meeting there was overwhelming opposition to both the proposed design and the proposed allowance of vehicles on the bridge. It is concerning that several of the proposed routes in the South Boston Seaport Strategic Transit Plan assumed some access over the Northern Avenue bridge, when there are still many outstanding concerns about that project. 

Thank you for the opportunity to comment on the plan. We look forward to working with you in the months ahead.

Sincerely,

Tom Ready, FPNA

Stacy Thompson, Executive Director, LivableStreets 

Stacey Beuttell, Executive Director, WalkBoston

Wendy Landman, Senior Policy Advisor, WalkBoston

Becca Wolfson, Executive Director, Boston Cyclists Union

Galen Mook, Executive Director, Massachusetts Bicycle Coalition

Jarred Johnson, Executive Director, TransitMatters

Cc Mayor Michelle Wu
Ed Flynn, District 2 City Councilor
Michael Flaherty, At Large City Councilor
Julia Mejia – At Large City Councilor
Ruthzee Louijeune – At Large City Councilor
MassDOT Secretary Jamey Tesler
MBTA General Manager Steve Poftak

Comments on Fenway Corners DPIR

Comments on Fenway Corners DPIR

March 30, 2022
Aisling Kerr, Project Manager
BPDA via email Aisling.Kerr@boston.gov

Re: Fenway Corners DPIR

Dear Ms. Kerr:

WalkBoston has attended project meetings and reviewed the DPIR for the Fenway Corners Project with respect to its impacts and benefits for people walking and using transit. 

We are happy to reiterate that we are pleased that the proponent is proposing significant improvements to the walking environment in the Fenway neighborhood and giving detailed attention to the needs of people walking, taking transit and bicycling. The proposed transformation of Jersey Street into a pedestrian-only space will provide an exciting new way to experience Fenway Park (on non-game days) and add amenities for residents and visitors to the Fenway neighborhood. We are also pleased to see that the Lansdowne Street building will be designed around a public gateway through the building which will someday allow connectivity through the Lansdowne block to provide a pedestrian connection with Kenmore Square. 

We support the proponent’s plans to modify the street system in and around the multi-site project in order to create more space for pedestrians and for people enjoying what will essentially become a new open space in the neighborhood.

We believe that the combination of street changes, walking, transit and biking improvements and attention to urban design provided by the project will provide benefits to both neighborhood residents and visitors. The proponent’s plans are consistent with the City’s goals of growing without adding significant new vehicle traffic to the City’s streets. 

Overall we believe the project will benefit pedestrians on the streets and sidewalks of the Fenway. We urge the proponent to continue working with WalkBoston and other advocates and with the City of Boston to refine several elements of the design as the project proceeds.

  • Sidewalk/Bus stop/Bike interactions – We appreciate that the project team has continued to assess the operation of Brookline Avenue with attention to the mix of bus, walking and bike operations. While the exact design and operation of Brookline Avenue is not yet certain, the good faith efforts of the design team are encouraging. We urge the proponent to continue working with WalkBoston, the Boston Disabilities Commission, the MBTA’s Office of Systemwide Accessibility, the Boston Transportation Department and the bicycle advocacy community to ensure that the designs meet the needs of all sidewalk, transit and street users.
  • Transit operations – In order to achieve the mode shares that the proponent, the residents of the Fenway, the employers in the area, the City and all of us interested in reducing GHG emissions hope for, the operations of the many bus routes in the neighborhood and throughout the region need to be improved and added to. As noted above, we are encouraged that the needs of bus riders are being given careful attention to ensure that they are enhanced by the changes in street operations and design. We hope that the proponent will continue to be a voice for better transit with the City and the MBTA.
  • Curb management – As noted in the DPIR, the management of buses, deliveries, TNCs, and short-term parking is critical to the smooth operations of the district’s streets and sidewalks. With the proposal to eliminate on street parking in several locations we believe that it will be incumbent on the proponent to develop a detailed management system that is clear, easy to use and actually used by the many delivery vehicles and short-term parkers who frequent the neighborhood. This is needed for both the businesses and business users of the neighborhood, and for the safety of people walking, biking and taking buses. When drivers stop in travel lanes and block the passage of other vehicles, people walking can find themselves crossing the street between stopped vehicles and confronted with frustrated drivers. We ask the proponent to provide an opportunity for interested members of the public to review the curb management plan prior to its finalization.
  • Parking – The supply of parking for the project will have a profound impact on the mode of travel that will be used by people accessing the site. We urge the developer and the City to work together to further reduce the number of parking spaces that will be provided. With the 5-7 year buildout period we are hopeful that the City, MBTA and MassDOT will make progress toward the investments in transit, walking and biking that will make is sensible to reduce the number of parking spaces in the project. 
  • Paving surfaces – Some of the sketches shown in public presentations continue to suggest paving stones or other uneven paving materials. We ask that all paving materials be fully accessible and comfortable for all people walking or using mobility assistance. We also ask that the proponent take into account the needs of providing good snow clearance on all of the sidewalks and also that they commit to providing such clearance.
  • Sense of welcome for all – The redesign and re-purposing of Jersey Street and all of the city blocks included in the project presents exciting opportunities for walkability. It also presents some challenges to ensuring that the spaces and places are not managed or curated in ways that could feel privatized or exclusive and less than fully welcoming to people of all races, incomes and ages. We urge the proponent to continue working with diverse community groups and individuals from a variety of Boston neighborhoods to ensure that the sense of welcome includes everyone.

Thank you for the opportunity to provide comments.

Sincerely, 

Wendy Landman
Senior Policy Advisor

Comments on MassDOT Maffa Way + Mystic Ave Bridge Project (File No. 607670)

Comments on MassDOT Maffa Way + Mystic Ave Bridge Project (File No. 607670)

March 22, 2022

Carrie E. Lavallee, P.E.,
Acting Chief Engineer

Suite 6340, 10 Park Plaza, Boston, MA 02116

via e-mail to dot.feedback.highway@state.ma.us

Attention: Major Projects, Project File No. 607670

Dear Ms. Lavallee,

I attended the public meeting for the MassDOT Maffa Way / Mystic Ave Bridge Project in Somerville (near Sullivan Square) earlier this month. There were a few questions from the audience and a discussion about vehicle speed which seemed to show a real disconnect between MassDOT’s Safe Speed Management guidance and the way that this project is being designed.

This project is set to be completed in 2027, and will rebuild the bridges / associated roadways. There are a lot of project elements that will help to make the roads and sidewalks safer for biking and walking and improve access to the MBTA station. However, when I brought up the recently released speed guidance that describes target speeds, it was not very well received by the project team. The default speed in both Somerville and Boston is 25mph. This project is using a design speed of 35mph, after doing a speed study and seeing that the 85% speed on the existing roadway was ~32mph. At least three other attendees also commented that the design speed is way too high.

Good points were made that MassDOT should be designing a road for what is needed, and not repeating the design problems that are out there right now which allow people to drive way too fast, especially at off peak times. MassDOT & all MassDOT consultants should be setting the example for the rest of Massachusetts about how projects can incorporate the recently released Safe Speed Management guidance through setting target speeds for a reconstructed roadway rather than relying exclusively on the 85th percentile of the existing road.

Thank you,

Brendan Kearney
Deputy Director, WalkBoston