July 24, 2019

Laura Dietz
Department of Conservation and Recreation
251 Causeway Street
Boston, Massachusetts 02114

Dear Ms. Dietz,

WalkBoston has reviewed the amendments to “302 CMR 11.00: Parkways, Traffic, and Pedestrian Rules” and “302 CMR 12.00: Parks and Recreation Rules,” and attended the public hearing on July 2, 2019 in Brighton.

This process should be put on hold until laws on micro-mobility and e-bikes are established by the legislature so there is cohesion between the law and regulations.

We also have some questions and comments based on our review:

• What data are these proposed changes based on?
• Are there any successes or failures in other states that MA is trying to emulate or avoid?
• We have concerns about setting a limit of 20mph for shared use pathways. How was that speed limit established, and what is it based on? We need context sensitive speed limits, not one limit for all places. A 20mph limit is a speed limit that is recommended on residential streets, which include sidewalks for separation.
• There are long section of definitions including BOULEVARD, PARKWAY, ROADWAY, STREET, but there is no definition of the different types of trails. Some of the suggested regulations describe ‘improved or natural surface trail’ vs. other types of trails; with no easy definition, this could lead to confusion.
• Section 12.12(4) states they are ‘not permitted on improved trails less than 8 feet,’ would this mean certain sections of contiguous trails would allow/prohibit use?
  • Additionally, while we recognize the intent to create safe areas where there could be conflict, we fear that setting a regulation by width could have unintended consequences for future trail development.
• The section on Violations/Fines/Penalties only includes info about parking.

Thank you for the opportunity to provide comments.

Brendan Kearney
Communications Director