Tag: EEA 11202

WalkBoston Comments on 2022 MassDOT Snow and Ice Control Program EEA#11202

WalkBoston Comments on 2022 MassDOT Snow and Ice Control Program EEA#11202

February 6, 2023

Secretary Rebecca Tepper
Executive Office of Energy and Environmental Affairs

Attn via email: Eva Vaughan

Re:  2022 MassDOT Snow and Ice Control Program EEA#11202

Dear Secretary Tepper:

WalkBoston commented on MassDOT’s Environmental Status and Planning Report (ESPR) on Snow and Ice Control in 2018 and again in March 2021. Our 2021 comments were incorporated into the Certificate issued by EOEEA in 2021.

WalkBoston has continued to follow MassDOT’s efforts regarding the clearance of sidewalks, curb ramps and traffic islands that are under the agency’s jurisdiction, and we are pleased that the 2022 ESPR includes several new commitments to sidewalk snow clearance.

One important step that MassDOT has taken since 2021 is the provision of grant funding of up to $50,000 to help municipalities purchase snow removal equipment for pedestrian and bicyclist facilities through its Shared Streets and Spaces Grant Program. While not directed to MassDOT owned sidewalks, this program should help to increase sidewalk snow clearance on municipal sidewalks.

As stated on page 15 of the ESPR, approximately 43% of MassDOT roads have adjacent sidewalks amounting to approximately 1,300 miles of sidewalks located mostly in the central village and downtown areas of various communities. The new steps called out by MassDOT in the ESPR (pages ES-5 and 15) are the following:

  • New for the 2022/23 winter, MassDOT plans to hire more “seasonal” snow and ice employees that report directly to MassDOT to help with sidewalk clearing as well as other activities.
  • MassDOT will continue to evaluate vendor reimbursement rates and pay codes to enlist more contractors for sidewalk maintenance services and better reflect the variable snow removal efforts for large storms versus smaller storms.

When MassDOT reports on the outcomes of its 2022 ESPR we ask that the following information be included so that WalkBoston and others can see how successful the new efforts are at providing safe and accessible sidewalks.

  1. Provide a map showing the location of the 1,300 miles of MassDOT sidewalks, and indicate which of these miles were covered by work orders for clearance by MassDOT or its contractors.
  2. Include sidewalk clearance responsibilities in the table showing MassDOT SICP roles and responsibilities (Table 1.2 on page 6 of the report)
  3. Provide information about the cost of sidewalk snow clearance provided by MassDOT or its contractors – similar to that provided in Table 1.9 for lane miles.

We look forward to continuing to work with MassDOT on this important public safety and mobility issue.

Best regards,

Brendan Kearney

Deputy Director of Advocacy, WalkBoston

Continued emphasis on snow clearance for pedestrians!

Continued emphasis on snow clearance for pedestrians!

MassDOT’s recently published Snow and Ice Control Program details many of the steps that MassDOT will take to deal with the impacts of its application of chemicals on roadway, a required filing to the Massachusetts Executive Office of Environmental and Energy Affairs (EEA). 

In 2021, WalkBoston urged regulators to require MassDOT to include specific, trackable and verifiable progress toward meeting the scope of pedestrian needs in its next filing on the MassDOT Snow and Ice Control Program, and to use its own Pedestrian Plan commitments as the baseline for reporting. 

At the end of December 2022, MassDOT released an update, which includes these passages: 

  • “Chapter 1 provides an update on MassDOT’s roadway lane-miles and describes new measures to build capacity to address the snow and ice removal needs on sidewalks and pedestrian facilities as identified in the 2019 Pedestrian Transportation Plan and as requested by the WalkBoston following review of the 2022 ESPR SOW Plan.”
  • “New for the 2022/23 winter, MassDOT plans to hire more ‘seasonal’ snow and ice employees that report directly to MassDOT to help with sidewalk clearing as well as other activities. MassDOT will continue to evaluate vendor reimbursement rates and pay codes to enlist more contractors for sidewalk maintenance services and better reflect the variable snow removal efforts for large storms versus smaller storms. MassDOT also provides grant funding of up to $50,000 to help municipalities purchase snow removal equipment for pedestrian and bicyclist facilities through its Shared Streets and Spaces Grant Program. Details on eligible projects can be found at the following link: https://www.mass.gov/shared-streets-and-spaces-grant-program

We are pleased that MassDOT has made new commitments to improve their maintenance of state owned sidewalks. WalkBoston will follow up with MassDOT at the end of the 2022/23 winter season to learn how the new initiatives have been carried out, whether they have proved successful, and to find out whether the agency will plan any additional adjustments to continue making improvements. Check out the links below to read the report for yourself!


MassDOT Snow and Ice Control Program Comment Letter

MassDOT Snow and Ice Control Program Comment Letter

March 12, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs
Attn via email: Eva Murray

Re:  MassDOT Snow and Ice Control Program EEA#11202

Dear Secretary Theoharides:

WalkBoston commented on MassDOT’s Environmental Status and Planning Report (ESPR) on Snow and Ice Control in 2018 and has continued to follow the agency’s efforts regarding the clearance of sidewalks, curb ramps and traffic islands that are under MassDOT’s jurisdiction. While we do believe that MassDOT’s staff agree that sidewalk snow clearance is an important safety, equity and mobility issue, we are disappointed in their lack of progress since 2018.

Our comments reiterate this importance and report on some of the work that WalkBoston has done to urge MassDOT to take more effective planning and operational steps.

As laid out by MEPA in 2018 (page 4), MassDOT’s scope relative to sidewalks was as follows:

“The DSW for the 2022 ESPR should include a response to comments received on the FESPR. In its comments on the DESPR, WalkBoston requested that the ESPR include more information about snow and ice control measures for pedestrian facilities. The FESPR noted that MassDOT will soon complete a statewide Pedestrian Transportation Plan that will include recommendations for improving pedestrian conditions affected by snow and ice. Consistent with MassDOT’s policy to promote alternate modes of transportation, including walking and bicycling, and implementation of its Complete Streets design program, the 2022 ESPR should provide a summary of the findings and recommendations of the Pedestrian Transportation Plan and describe any snow and ice control measures that will be implemented by MassDOT to improve pedestrian conditions. The DSW for the 2022 ESPR should identify any additional analyses or tracking of salt use associated with pedestrian facilities that will be included in the ESPR consistent with the scope and purpose of the SICP ESPRs.”

The Statewide Pedestrian Transportation Plan was completed in 2019 and very clearly called out sidewalk snow clearance as critically important, and as one of the responsibilities for MassDOT to lead on as a transportation and equity issue. It also stated that MassDOT needs to assume responsibility for sidewalk snow removal for some roadways that are under MassDOT’s direct care and control. The text of the Plan which describes these responsibilities is shown below (highlights provided by WalkBoston).


With its abundance of historic town centers, compact neighborhoods, urban areas, and natural resources, Massachusetts is home to premier walking environments. However, conditions for walking vary widely from one place to another. A simple stroll can quickly turn challenging or even impossible in the face of discontinuous sidewalks, missing curb ramps, unplowed snow, or unsafe intersections.


Prioritize improvements for people walking by proactively addressing gaps and barriers that discourage walking and are known to increase likelihood of crashes. MassDOT shall address deficiencies– from sidewalks gaps and missing crosswalks, access to transit, and snow and ice removal, for example.


Initiative 5: Launch a year-round maintenance and operations plan for MassDOT-owned pedestrian facilities and support municipalities to do the same.

Year-round maintenance of pedestrian facilities ensures the continual comfort and safety of the people who use them, but also extends the lifespan of the facilities themselves. MassDOT has a comprehensive process for inventorying the condition of curb-to-curb roadway pavement and for clearing snow and ice on all roadways and bridges travelled by vehicles. This initiative establishes actions to add pedestrian facility maintenance and operations to this work. MassDOT is moving towards a proactive and systematic data collection strategy to identify facilities in need of attention. MassDOT has already gathered data on curb ramp condition as part of the Statewide ADA Transition Plan.


Action 2: Pilot a winter snow and ice removal initiative on pedestrian facilities in order to provide the basis for development of a comprehensive plan – and an understanding of potential barriers to make such a program permanent.

Measures for tracking progress (on Actions)

Note: Part of the initiative is defining the maintenance standards and operational plans for snow and ice removal that will apply to these measures.

  • Percentage of MassDOT pedestrian facilities that are covered by regular snow and ice operations
  • Equity check: Do certain populations live in areas where fewer pedestrian facilities are covered by regular snow and ice operations?

The Plan outlines significant and important attention to sidewalk snow and ice removal, and we applaud the Plan. However, MassDOT’s efforts to date have not improved sidewalk snow clearance rates on MassDOT-owned facilities. Our March 1, 2021 letter to MassDOT Highway Administrator Jonathan Gulliver is included below and outlines our disappointment in the progress since the 2019 Plan.

Specific comments regarding the Status Report that MassDOT submitted to MEPA in February 2021 

Page 2, Section 1.2 Organization and Format – We are disappointed that sidewalks are not called out here as a section and not mentioned as one of the issues to be addressed.

Section 2.1 Preliminary responses – A number of the preliminary responses are quite specific and note progress toward addressing the issues. Given the specificity of MassDOT’s Pedestrian Plan regarding sidewalk snow clearance, and the requirements in the MEPA Certificate, we think that MassDOT’s answer (shown below) is incomplete and does not accurately characterize the barriers described in a recent presentation by MassDOT to the Massachusetts Bicycle and Pedestrian Advisory Board (a Board established by legislation whose members are appointed by the Governor) where staff indicated that MassDOT had not been able to secure contractors to clear additional sidewalks, or enter into meaningful agreements with municipalities to clear MassDOT-owned facilities.

MassDOT Answer (page 6 of the update)In the last few years, MassDOT has committed additional resources to provide snow and ice control on approximately 10% of the sidewalks adjacent to their roadways focusing on key areas with relatively high pedestrian usage. This effort is in the early stages of development and MassDOT will likely add more sidewalks into its winter maintenance program as resources become available. The status of this effort will be updated in the 2022 ESPR.

Following the MABPAB meeting (January 27, 2021) WalkBoston reached out to MassDOT staff to secure clarification on progress on sidewalk clearance. We followed this up with a letter to the Highway Administrator Jonathan Gulliver and are awaiting his response.

Forwarded message ———

From: Stacey Beuttell <sbeuttell@walkboston.org>

Date: Mon, Mar 1, 2021 at 11:12 AM

Subject: MassDOT Sidewalk Snow Removal Pilot

To: <Jonathan.Gulliver@dot.state.ma.us>

Cc: Jacqueline DeWolfe (DOT) <jacqueline.dewolfe@state.ma.us>

Hi Jonathan. 

I wanted to check in with you regarding MassDOT’s sidewalk snow shoveling pilot program that is now in its second year. Several members of the MassDOT Operations and Maintenance team recently updated MABPAB on the current status of the program and relayed the many barriers that have prevented MassDOT from entering into meaningful agreements with vendors to clear MassDOT-owned sidewalks. They reported that only 8.7% of MassDOT-owned sidewalks are currently being cleared by either MassDOT staff or by contractors. Furthermore, they reported that despite making changes to the sidewalk snow removal RFP this year, no qualified vendors applied for the contract. So, needless to say, people have been unable to walk safely on most MassDOT sidewalks throughout this snowy winter. I’m reaching out to see if there are ways WalkBoston can help with this issue, one that we feel is vitally important for year-round safe walking across the state.

I followed up with Jackie DeWolfe who suggested that I reach out to you. She reiterated MassDOT’s commitment to clearing sidewalks of ice and snow, and suggested that some of the barriers are outside of MassDOT’s control – for example, lack of labor market for sidewalk snow removal; and varying rules and capacities within municipalities to clear sidewalks. WalkBoston is eager and excited to find ways that we can support MassDOT and we are hoping to better understand the contract/municipal agreement issues and to get more sidewalks plowed. What next steps do you suggest we take to better understand the barriers and MassDOT’s work to date to overcome them? I would be happy to set up a Zoom call to discuss these questions with you. 

We know that this is an incredibly complex issue to solve. We know that you are likely as disappointed that the pilot program has now stalled for two snow seasons, as we in the advocacy community are, due to vendor/contract issues. I look forward to talking with you and discussing ways we can support forward movement on this important MassDOT priority.

Thanks Jonathan. I hope you have a good week.

Stacey Beuttell

We urge MEPA to require MassDOT to include specific, trackable and documented progress toward meeting the scope of pedestrian needs in its next filing on the MassDOT Snow and Ice Control Program, and to use its own Pedestrian Plan commitments as the baseline for reporting.

Thank you for the opportunity to comment on this critical issue for the safety, equity and mobility of Massachusetts residents.

WalkBoston would be pleased to answer any questions you may have about our comments.


Stacey Beuttell                                                                  Wendy Landman
Executive Director                                                           Senior Policy Advisor

Comments on MassDOT Snow and Ice Control Program 2017 EEA# 11202

Comments on MassDOT Snow and Ice Control Program 2017 EEA# 11202

August 9, 2017

Secretary Matthew Beaton
Executive Office of Environmental Affairs, MEPA Office
Attn: Alex Strysky
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Comments on MassDOT Snow and Ice Control Program 2017 Environmental Status and Planning Report EEA# 11202

Dear Secretary Beaton:

WalkBoston appreciates the opportunity to comment on the Snow and Ice Control Program of MassDOT. We are commenting because pedestrian issues are not addressed in the Report. We provided similar comments in 2006, to the then Mass Highway Department.

While MassDOT has made significant strides to incorporate the needs of pedestrians into many of their project designs and safety programs, we are disappointed that the important accessibility, safety and mobility issues that un-­‐shoveled sidewalks, crosswalks and safety islands pose for pedestrians has still not been addressed in this document.

The Report covers many of the steps that the MassDOT will take to deal with the impacts of its application of chemicals on roadways. It discusses in detail the impacts that these materials have on pavement and the relative degree of effectiveness that the materials exhibit when removing snow and ice. It describes procedures that snow plow operators (whether state employees or service-­‐providers hired by the state) must follow, along with ways that the state will oversee the operations associated with snow plowing. In several of these discussions MassDOT comes tantalizingly close to describing potential impacts on pedestrian movement, yet there is no explicit acknowledgement that pedestrians have a stake in the way the state removes ice and snow from roadways and to the relationship between roadway and sidewalk snow and ice clearance. The only mention of pedestrians in the document is where MassDOT indicates that DCR has retained responsibility for sidewalks adjacent to a number of roadways where MassDOT has assumed responsibility for the vehicular travel way and that the MBTA has a plan for its facilities.

The impact of roadway snow and ice clearance on pedestrians
Pedestrians are clearly affected by the removal of snow from roadways and sidewalks and the effects of inadequate clearance that results in unsafe conditions for walking. After a snowfall in Massachusetts, it is possible to view city or town streets where the roadways are well plowed, but the sidewalks are impassable. Common public services such as postal deliveries or meals on wheels can be disrupted. Commuters and school children find their routes blocked. Un-­‐cleared sidewalks parallel to snow mounds can force pedestrians onto the street where pedestrian-­‐ automobile crashes are far more likely to occur. Even where sidewalks are cleared, pedestrian access at intersections is frequently blocked by roadway-­‐related snow mounds that impede safe walking through the intersection and un-­‐cleared snow mounds can prevent pedestrians and drivers from seeing each other clearly at intersection approaches.

The simple activity of walking is dramatically altered by the presence of snow. Snow mounds present a physical challenge to pedestrians, and walkers who are trying to cross mounds of snow to get to a safe walking route may have their attention diverted away from oncoming traffic. Intersections clogged with snow or snowmelt can challenge pedestrians trying to cross, again causing temporary diversion of attention from oncoming traffic. Drivers may not be able to see pedestrians forced onto roadways.

Sidewalks are found along many state roads throughout the Commonwealth, and some roads that were originally constructed without sidewalks now have them as a result of the continuing urbanization and suburbanization of the state. Adding sidewalks is now required for state roads as they are rebuilt and they are thus a standard element of the MassDOT roadway network.

The importance of providing safe pedestrian access in all seasons cannot be taken lightly. It is a matter of public safety, adequate transportation, social justice (many of our citizens who are pedestrian and transit-­‐dependent are lower income or elderly), and economic well being (we discourage elders and the disabled from staying in Massachusetts if they feel isolated and home-­‐ bound by wintry conditions).

The lack of sidewalk guidance does not seem to conform to the MHD Project Development and Design Guide, 2006 edition, which states:

“MassHighway, in its role as steward of our roadways, must consider a broad range of factors in maintaining (emphasis added) or improving this system, including:
• Safety for all users
• Functionality – the need for access and mobility
• Accessibility for people with disabilities…
• Input and participation from local constituents …”

The manual quotes state law:

“Chapter 87 of the Acts of 1996 requires MassHighway to ‘make all reasonable provisions for the accommodation of bicycle and pedestrian traffic…’”

(Section 1.2.1, p. 1-­‐3) The manual continues with this Guiding Principle:

“Multimodal consideration – to ensure that the safety and mobility of all users of the transportation system (pedestrians, bicyclists and drivers) are considered equally through all phases of a project so that even the most vulnerable (e.g., children and the elderly) can feel and be safe within the public right of way….”

Section 1.2 Guiding Principles of the Guidebook, detailed in Section 1.2.1, p. 1-­‐3. Citing MassDOT’s 2017 policies as reflected on the current website,

“MassDOT is updating the Massachusetts Pedestrian Transportation Plan to improve conditions for walking throughout the Commonwealth.”

One of the core goals noted is to

“Identify policies and model practices to improve maintenance, year-­‐round usability and state of good repair of existing and planned pedestrian infrastructure.”

We urge MEPA to require MassDOT to explicitly incorporate policies and practices related to sidewalk, curb ramp and crossing island snow clearance in its Snow and Ice Control Program. The Program should address the issues noted below (much of the text is copied largely verbatim from WalkBoston’s 2006 comment letter).

Safety for both drivers and pedestrians
The state has determined that highway safety and vehicle mobility are high priority reasons for snow and ice removal. Clearing only the road is insufficient as a method for providing safety. Pedestrians crossing roadways or walking within the roadway constitute significant dangers for both drivers and themselves. The extent to which pedestrians use roadway pavements for walking is greatly expanded when sidewalks are left un-­‐cleared or when roadside snow mounds force people to clamber over them to cross streets. Many miles of MHD (now MassDOT in each instance below) roadways are paralleled by sidewalks and are thus critical components of the pedestrian (and transit) transportation networks.

Development of a protocol for determining who will be responsible for sidewalk snow clearance on MassDOT roadways
Sidewalk clearance responsibilities may well fall to several different parties including MassDOT, local municipalities, other state or local agencies, or private abutters. In order to “ensure the safety and mobility of all users of the transportation system,” this responsibility must be assigned, managed and enforced throughout the state. As the owner and operator of this transportation network, MHD should assume the job of leading the effort to determine how and by whom the sidewalks will be cleared.

The right of way as a basis for snow and ice removal
Municipalities throughout Massachusetts remove snow and ice from local roadways and establish methods for removing snow and ice from sidewalks. Yet the state does not take on the same responsibility for its roadways. Thus, local jurisdictions must provide for snow and ice removal from sidewalks along state roadways without substantial state assistance. Without coordination between the state and the municipalities, several issues emerge:

  1.  Intersections. The maintenance of a safe pedestrian passageway is critical at street crossings. The crossings are often blocked by snow plowing procedures that simply pile up snow evenly along the road, covering sidewalks, handicapped ramps and street corners, and forcing pedestrians to walk in the roadways. The responsibilities of the state and its agents in clearing intersections – including pedestrian access through the intersection – should be spelled out. Attention to this issue can help municipalities cope with comprehensive snow removal for sidewalks.
  2. Roadway use by walkers. When the state or its agents clear roadways of snow, safe pedestrian passage must be maintained. If the roadway is temporarily used as a substitute sidewalk because sidewalks have not been cleared pedestrian and vehicular safety is compromised. Snow removal frequently results in substantial mounds of snow paralleling the state highway that, in many cases, block the sidewalks and driveways connected to the roadway. Snow mounding as a method of disposal may exacerbate the problem of clearing sidewalks because of the sheer volume of the snow plowed onto the sidewalks.
  3. Planning. Streets can be designed to make plowing easier. Sidewalks might be placed at a distance from the roadway that is sufficient to accommodate snow plowed from the street. Snow fences could be located to control snow buildup on pedestrian facilities and help reduce 4 removal costs. The state should establish guidelines for improved design. Pedestrian safety islands should be designed to remain snow-­‐free after plowing operations.
  4. Research. The Report contains documentation of lane-­‐miles plowed under state responsibility. Perhaps research is necessary to document pedestrian miles on sidewalks along state highways and to show how state snow plowing policies affect pedestrians and how those policies need to be amended or supplemented. In addition to providing a plan for ensuring the clearance of sidewalks, It would be useful to know what financial and technical assistance the state might provide for communities and pedestrians during snowy conditions along state roads through a variety of funding sources such as CMAQ, safety funds or hazard elimination funds.

Coordination of local and state efforts
The method by which state and local coordination takes place is described briefly in the 2006 GEIR. This issue has not been addressed in the 2017 report, but remains an important issue for pedestrian safety.

  1. Division of responsibilities. As noted above, MassDOT should determine sidewalk snow-­‐ clearing responsibilities and how state, local and private entities will divide the work. A detailed plan for coordination is essential to determine precisely how the responsibilities will be divided, especially at locations where different responsibilities will abut or overlap. For example, at intersections where there are sidewalk connections into intersections, pedestrian crossings through intersections, and sidewalks along the roadways and across driveways. It is important for MassDOT to include information about pedestrian issues for inclusion in the plow route schedule each fall and for information to be disseminated by the MassDOT Districts.
  2. Sidewalk snow removal procedures. Written procedures can help clarify how snow is to be removed from sidewalks along state roads by agents other than the MassDOT. The state, municipalities or other state agencies can establish priority sidewalks that must be maintained for walkers right from the start of a snow emergency. One model has been prepared by the DCR, which works with the MassDOT to clear certain of its roadways. The state clears curb-­‐to-­‐ curb, and the DCR clears the sidewalks according to a predetermined priority rating assigned to each sidewalk. Some communities (e.g. Concord) clear snow from sidewalks along state roads according to a plan that has been developed in conjunction with the school department to facilitate safe access to schools. Priorities may need to be established for sidewalks leading to schools, transit, hospitals and clinics, business concentrations, and public services such as police and fire stations, as well as based on the density of pedestrian use.
  3. Bartering. A bartering process was described in the 2006 GEIR (Section 2.5.3, p. 29) as an informal method of coordinating operations, with the state taking on some municipal responsibilities. This method of coordination could be used to establish procedures for local communities. Coordination might be embedded in written agreements between the state and the cities and towns that define responsibilities for the details of snow removal. This process is no longer included in the Guide and we are curious how it has been replaced.
  4. Communication with the public. The public should be informed of policy decisions concerning snow removal on sidewalks, streets and at intersections, so that individuals can plan routes to work or school or for other purposes. One method is to place information delineating responsibilities on-­‐line so that can be widely distributed. A good example of delineating agency responsibilities for snow removal is laid out in the Department of Conservation and Recreation’s website at: http://eoeea.maps.arcgis.com/apps/SimpleViewer/index.html?appid=4a64ec9cf8ac4bb5a5bc 97e5e443e798 By laying out snow removal intentions, it may be possible to avert tragedies involving pedestrians walking in roadways.

Thank you for the opportunity to comment on the Report. Please feel free to contact us for clarification or additional comments. We would be very pleased to work with MHD on this important issue.


Wendy Landman
Executive Director

Cc:   Stephanie Pollack, MassDOT Secretary
Sam Salfity Director of SICP Operations
Jonathan Gulliver, Acting Highway Commissioner
Kate Fichter, MassDOT Assistant Secretary for Policy Coordination
Jackie DeWolfe, MassDOT Director of Sustainable Mobility
Pete Sutton, MassDOT Bicycle and Pedestrian Program Coordinator