Category: Comment Letter

Comments on Memorial Drive Phase III

Comments on Memorial Drive Phase III

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January 27, 2022

Secretary of the Executive Office of Energy & Environmental Affairs

100 Cambridge Street, Suite 900
Boston, MA 02114
Attn: MEPA Office, Christina Lyons

RE: Memorial Drive Phase III – Environmental Notification Form 16495

Dear Secretary Theoharides:

WalkBoston is Massachusetts’ primary pedestrian advocacy organization, working across the Commonwealth to make it safer and easier for people to walk for all activities of daily living such as access to transit, school and jobs. We are writing to you to show support for the MassDCR road diet of the 0.8-mile section of Memorial Drive from Eliot Bridge east to the intersection of Memorial Drive and John F. Kennedy Street near Harvard Square. We are happy to see this project move forward since it was last discussed publicly in the Summer of 2019.

We appreciate that there is continued attention to separating users by mode whenever possible on MassDCR facilities and within the Charles River Basin, following the recommendations from the 2002 Charles River Basin Plan. Converting the existing 6.5-foot-wide path to a 10-foot shared use path paired with a 5-foot wide stabilized gravel path for people walking and running will help reduce conflicts. 

We also applaud you for the addition of mid-block crossings into the project area, an opportunity unlocked by the road diet’s narrower cross-section. There is a new mid-block pedestrian crossing proposed on Memorial Drive near Sparks Street and Mt. Auburn, which provides a direct link to the MBTA Bus Stop for Bus 71 and 73 to further enhance accessibility to this important park and transportation corridor for transit riders. An additional mid-block crossing is also proposed at Memorial Drive near University Road, closer to JFK. Both pedestrian crossings will include rapid flashing beacon lights (RRFBs) to alert drivers to crossing pedestrians. 

With a projected increase in biking and e-bike usage in the coming years, we encourage you to highlight any possible conflict zones between people walking and biking with paint or signage to help minimize these conflicts, particularly at the new mid-block crossings. 

Thank you for the opportunity to comment. 

Stacey Beuttell, AICP

Executive Director, WalkBoston

Comment Letter Re: Support for H.3437, An Act requiring backup cameras on certain vehicles

Comment Letter Re: Support for H.3437, An Act requiring backup cameras on certain vehicles

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January 18th, 2022

Joint Committee on Transportation
Representative William Straus, Chair

Re: Support for H.3437, An Act requiring backup cameras on certain vehicles

Dear Chairman Straus, Vice Chairs Keenan and Devers, and members of the committee,

Members of the Massachusetts Vision Zero Coalition respectfully request that the committee report out favorably on H.3437 An Act requiring backup cameras on certain vehicles.

H.3437 An Act requiring backup cameras on certain vehicles would require the Registrar of Motor Vehicles to include regulations around having rear visibility camera systems, or “backup” cameras for motor vehicles over 10,000 pounds that are owned or leased by the commonwealth or a city or town of the commonwealth. As of May 2018, the National Highway Traffic Safety Administration requires all new vehicles to be manufactured with backup cameras. However, this only applies to vehicles under 10,000 pounds, meaning large trucks are not included in this law. These large trucks have significant blind spots¹, making it challenging for drivers to see what is behind them when backing up. Requiring backup cameras could be an important safety measure for preventing backover crashes involving large trucks and vehicles, and protecting vulnerable road users like people walking and biking—particularly children and older adults who are most impacted by these kinds of crashes².

In Massachusetts over the last five years (2017-2021), there have been 33 crashes involving trucks backing up and people walking, resulting in 2 fatalities³. Additionally, two workers at a construction site in Boston were struck and killed when a co-worker backed up a truck and pushed them into a trench in February 2021. While the ownership history of all of these trucks is unknown, we are confident that beginning with state- and municipally-owned vehicles will act as a model for private operators to install video technology; the impact of which will help prevent the needless loss of life of people walking on roadways and sidewalks in Massachusetts.

Implementing these requirements, particularly when paired with other truck safety measures included in H.3549 An Act to reduce traffic fatalities, would make measurable improvements for the safety of vulnerable road users around large trucks.

Thank you for your time and consideration.

Sincerely,

The Massachusetts Vision Zero Coalition

Cheryl Pavlik, Allston Brighton Health Collaborative
Galen Mook, Massachusetts Bicycle Coalition
Jarred Johnson, TransitMatters
Adam Shutes, WalkUP Roslindale
Becca Wolfson, Boston Cyclists Union
Stacey Beuttell, WalkBoston
Janie Katz-Christy, Green Streets Initiative
Emily Stein, Safe Roads Alliance
Alex Epstein, Somerville Alliance for Safe Streets
Julia Wallerce, Institute for Transportation and Development Policy
Catherine Gleason, LivableStreets Alliance
Josh Ostroff, Transportation for Massachusetts

¹ Federal Motor Carrier Safety Administration (https://www.fmcsa.dot.gov/ourroads/large-blind-spots)
² NHTSA Report on Backover Crashes (https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/811144.pdf)
³ MassDOT IMPACT portal (https://apps.impact.dot.state.ma.us/cdp/home)

Comment Letter Re: Opposition to H.3399, An Act relative to increasing penalties for texting and driving

Comment Letter Re: Opposition to H.3399, An Act relative to increasing penalties for texting and driving

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January 18th, 2022

Joint Committee on Transportation
Representative William Straus, Chair

Re: Opposition to H.3399, An Act relative to increasing penalties for texting and driving

Dear Chairman Straus, Vice Chairs Keenan and Devers, and members of the committee,

Members of the Massachusetts Vision Zero Coalition respectfully oppose H.3399 An Act relative to increasing penalties for texting and driving.

H.3399 An Act relative to increasing penalties for texting and driving would increase fees from a first offense from $100 to $250, and would escalate at a greater rate for subsequent offenses—$500 for a second and$750 for a third. In addition to increased fines, a license suspension of 90 days could be issued for the first offense of texting and driving. This escalation of harmful and punitive measures is a problem for a few reasons:

  1. Research has shown that increasing the severity of punishment is an ineffective deterrent to crime, and often worsens racial and economic disparities¹, suggesting that increasing penalties would not have the intended effect of lowering the number of people texting and driving.
  2. Data on the hands free law in MA has shown that this law is being inequitably enforced². In traffic stops for using a phone while driving between April and December 2019, Black, Hispanic, and Asian people were more likely to be issued citations than white people for the same infraction. The increased punitive measures proposed in this legislation will disproportionately burden Black drivers and drivers of color in Massachusetts.
  3. These large fines can be debilitating for lower income individuals who may not be able to afford them, and as the law is currently written, non-payment of these fines can compound with late fees and can result in debt-based license suspensions and potential incarceration—an inequitable and ineffective practice that forces individuals to make the impossible choice between driving on a suspended license, risking additional fines and incarceration, or risk being unable to get to work and lose the income they need to access and afford essential services, much less pay their fine (note: there are other bills in this committee that would eliminate this practice that the Coalition is supportive of—H.3453 and S.2304).

While we know that distracted driving is a safety concern on our roads, we don’t believe these punitive measures are the solution. We ask that the committee take this into account with respect to this proposed legislation and oppose H.3399.

Thank you for your time and consideration.

Sincerely,

The Massachusetts Vision Zero Coalition

Cheryl Pavlik, Allston Brighton Health Collaborative
Jarred Johnson, TransitMatters
Becca Wolfson, Boston Cyclists Union
Stacey Beuttell, WalkBoston
Emily Stein, Safe Roads Alliance
Julia Wallerce, Institute for Transportation and Development Policy
Catherine Gleason, LivableStreets Alliance
Galen Mook, Massachusetts Bicycle Coalition
Adam Shutes, WalkUP Roslindale

¹ National Institute of Justice (https://nij.ojp.gov/topics/articles/five-things-about-deterrence)
² Hands Free Data in MA (https://www.wcvb.com/article/massachusetts-data-white-drivers-got-more-breaks-for-hands-free-cellphone-violations/35421474#)

Testimony To Joint Committee On Transportation In Support Of An Act to Reduce Traffic Fatalities / Against Jaywalking Bill

Testimony To Joint Committee On Transportation In Support Of An Act to Reduce Traffic Fatalities / Against Jaywalking Bill

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Testimony as prepared for the Joint Committee on Transportation scheduled on Thursday, October 14, 2021 at 10:00 a.m. conducted via Microsoft Teams. To submit written testimony, you can submit it through the committee link above. Online testimony will be accepted until Friday, October 15 at 5:00 PM. Consider sending your testimony to your elected officials as well.

My name is Brendan Kearney, and I’m the Deputy Director of WalkBoston, Massachusetts’ statewide pedestrian advocacy organization, also speaking on behalf of the MA Vision Zero Coalition in support of the concepts behind An Act to Reduce Traffic Fatalities bills, but especially bill H3549 filed by Representatives Moran and Representative Straus. We are opposed to H3470, an act to prevent jaywalking. 

We’re also opposed to the sidewalk robot bills: H.3583/S.2308 An Act relative to mobile carrying devices & S.2256/H.3482 An Act relative to personal delivery devices. (Click here to read testimony against similar legislation from 2019.)

H3549 Act to Reduce Traffic Fatalities

We believe this bill has many good provisions that will make our streets safer, including: 

  • Side guards and backup cameras for large trucks,
  • Definition of vulnerable road user and 3 foot passing language, 
  • Standardized crash reports,
  • Two fixes to speed limits, including: 
    • Allowing MassDOT to improve the safety of workers in active construction zones by establish speed limits without conducting an engineering study, 
    • Allowing state roads within a city/town that have opted into the 25mph default municipal speed limit to also be changed to match that 25mph limit. 

H3549 does not include language that would require a rear red light AND a rear reflector. Currently the law requires one or the other. Bikes are manufactured with a reflector, and users often add a light. Eliza from the Boston Cyclists’ Union will share more information about the importance of preserving this as an OR statement.  

H3470 An Act to Prevent Jaywalking

We are opposed to this bill, and testified against this similar legislation in 2017. There are a number of pieces within this proposal that are concerning.

This bill does not increase safety – it increases fines. Those fines are increased even more if you have a phone or headphones. This bill would also make crossing outside of a marked crosswalk illegal.

First: Distracted walking is a distraction.

When Toronto was examining a similar ‘distracted walking’ bill a few years ago, the Globe and Mail published an editorial that referenced electronic devices in the hands of walkers were a factor in just 25 of 23,240 pedestrian deaths in the US from 2010-14 (FARS = Fatality Analysis Reporting System). The editorial was titled, “All those pedestrian deaths? It’s the cars, stupid.”

Second: making it illegal to cross outside of a crosswalk is not realistic. 

It is legal to cross anywhere outside of a marked crosswalk if you are at least 300ft from a crosswalk or signalized intersection. That is a reflection of how we all use our streets and how our communities are designed. 

For example: I live in Framingham on Central Street. There is a sidewalk on one side of the street – on the side opposite our house. I cross when there are no drivers coming, or when someone yields for me. It is at least a mile between the crosswalks on our street. It would be unsafe to try and walk on the narrow 30 mph street with traffic to my back to try and get to the nearest crosswalk ¼ of a mile down the street – an act which in itself would be technically against the law: if there is a sidewalk present along a street, I’m supposed to walk on it. If there wasn’t a sidewalk, the law says I should walk against traffic.

This is not an extreme example – that is literally the view from my front door, and that’s the reality of many of our municipalities across Massachusetts. The term jaywalking was created by the auto industry in the 1920s to shift blame away from drivers who were hitting and killing people. 100 years later it has proven to be one of the most successful propaganda and marketing efforts of all time. 

Finally, there are real equity concerns around jaywalking laws.

Jaywalking laws have been found to lead to biased enforcement. Other places across the country, like Virginia, are working toward decriminalizing jaywalking. ProPublica released a series “Walking While Black” a few years ago that found black people in Jacksonville, Florida were 3x as likely to be stopped and cited as white people. Similar patterns have been seen in many other places; Streetsblog reported last year that 89% of people issued jaywalk citations in New York were Black and brown. 

This Friday at 2pm, the national organization America Walks is holding a webinar entitled “How to Take on Harmful Jaywalking Laws.” The host and moderator is Charles T. Brown from Equitable Cities, an award-winning expert in planning and policy. I’m happy to share the link to Friday’s America Walks webinar via email with the committee afterwards. 

Since I’ve talked at length, I will share our concerns with the sidewalk robot bills in a letter to the committee afterwards. (Testimony against similar legislation from 2019.) In brief: We believe these types of vehicles belong in the street, and not sharing already constrained sidewalks. 

Thank you for your time.

Testimony to Joint Committee on Public Safety and Homeland Security in support of Automated Enforcement

Testimony to Joint Committee on Public Safety and Homeland Security in support of Automated Enforcement

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Testimony as prepared for the Joint Committee on Public Safety and Homeland Security scheduled on Wednesday, October 13, 2021 at 11:00 a.m. conducted via Microsoft Teams. To submit written testimony, please email it to Dave McNeill (david.mcneill@mahouse.gov) and Cara Libman (cara.libman@masenate.gov). Consider adding your elected officials as well. For more talking points to consider from today’s hearing, take a look at this post from MA Vision Zero Coalition.

My name is Brendan Kearney, and I’m the Deputy Director of WalkBoston, Massachusetts’ statewide pedestrian advocacy organization, also speaking on behalf of the MA Vision Zero Coalition in support of these automated enforcement bills, S1545 and H2426 and H2532. Thank you for holding this hearing.

First: There has been an increase in speeding during COVID.

According to the Governor’s Highway Safety Association, during 2020, when much of the country was under shelter-in-place restrictions due to the Covid-19 pandemic, the rate of overall traffic fatalities jumped 20% from 2019. Said another way, with a 16.5% reduction in vehicle miles traveled (VMT) nationwide, the rate of drivers striking and killing pedestrians jumped to 2.2 deaths per VMT – an increase from 1.8 deaths in 2019. 

Potential causes include speeding, distracted and impaired driving. With fewer drivers on the road, there was more space to speed. Here in Massachusetts, MassDOT and others recognized this trend: High driving speeds contributed to a doubled roadway fatality rate in the month of April 2020 in Massachusetts – and MassDOT began a communications campaign to remind people that times have changed, but speed limits haven’t. 

Second: There is a need for equitable enforcement. 

In June 2020, WGBH reported out data showing that black people in Boston accounted for 70% of police stops despite being 25% of the population. We believe that it is now time to pass an equitable automated enforcement law that would allow municipalities to install red light and speed cameras in high crash corridors with a robust community engagement plan. 

We hope that you will move automated enforcement bills forward and out of committee, and have a few recommendations to help improve them. 

  • Reconsider the population requirements to participate: since all the AE bills are municipal opt-in, it doesn’t seem that there should be a population requirement for communities to take part. A community of any size should be eligible for this program. Lots of rural roads in our state have huge speeding programs, and those places should be able to opt-in if they so choose. For example, as a statewide pedestrian organization, WalkBoston has worked with Rural communities that are also concerned about speeding including Williamsburg, Huntington, Blandford, Chesterfield, Cummington, and Goshen. There had been changes made during debate last February, so we just hope this can be clarified to ensure any community can opt-in. 
  • We support fines that are non-escalating. The primary intent is to change drivers’ behavior. New York recently issued a report that examined their speed camera program from a seven year period: 2014-2020. In 2020, 52% of drivers who received a speeding ticket from a camera never got another one that year, while 20% only got one more (see p.14 of report). This suggests that the system led almost three-quarters of speeding drivers to change their behavior. 

Thank you for the opportunity to comment. We hope that you can take these recommendations into consideration when consolidating the 3 automated enforcement bills into one bill that we hope will move forward and out of committee.