Tag: USDOT

Joint support letter for MassDOT proposal to USDOT’s FY2022 Multimodal Project Discretionary Grant Program

Joint support letter for MassDOT proposal to USDOT’s FY2022 Multimodal Project Discretionary Grant Program

Joint support letter for MassDOT proposal to USDOT’s FY2022 Multimodal Project Discretionary Grant Program

May 23, 2022

The Honorable Pete Buttigieg
Secretary of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590

Dear Secretary Buttigieg:

Please accept this letter from a broad coalition of transportation, environmental, business, and community stakeholders in support of the Massachusetts Department of Transportation (MassDOT) application for USDOT’s FY2022 Multimodal Project Discretionary Grant (MPDG) assistance to help fund its I-90 Allston Multimodal Project located in the City of Boston.

The I-90 Allston Multimodal Project creates an opportunity to dramatically improve livability and connectivity for residents of Boston’s Allston neighborhood, an environmental justice population defined by Massachusetts law, while enhancing regional mobility and creating a significant new multimodal passenger train station for the Massachusetts Bay Transportation Authority (MBTA). In 1965, Massachusetts officials opened the Allston section of I-90, shoehorning an eight-lane elevated highway between Boston University and the Charles River, dividing a vibrant working-class community, shutting down important passenger rail stations, and wounding important riverfront habitat in the process. The highway was designed and built prior to the protections now provided by the National Environmental Policy Act, and financed without federal funding through bonds secured by tolls. Some 60 years later, Boston still endures harmful impacts from this obsolete, failed transportation policy that placed a highway above the needs of neighborhoods and the environment.

The Allston Viaduct is nearing the end of its useful lifespan. Since the spring of 2014, MassDOT has been developing a concept to replace the Allston Interchange and Viaduct. The MassDOT team worked with a Task Force composed of local residents, advocates, elected and appointed officials, representatives of local institutions and businesses, and the Allston community at-large – many of whom have signed onto this support letter. In September 2021, MassDOT identified the Modified At- Grade Option as the focus for the Allston I-90 MultiModal Project and selected the Modified At-Grade design–the clear consensus option–as its preferred alternative. We are committed to continuing our work with MassDOT to see the project to completion – building a future where the needs of public transit riders, cyclists, pedestrians, and the health of the river are as important as motorists traveling on this section of interstate.

The I-90 Allston Multimodal Project fulfills each of the USDOT’s six selection criteria in terms of project outcomes:

A. Safety: Addresses known safety problems and helps to protect both motorized and non-motorized users. The Modified At-Grade Option addresses known safety problems and protects motorized users by providing the safest horizontal alignment and vertical profile for the replacement of the functionally deficient existing I-90 viaduct by reducing curves and steep grades, which will reduce excessive speeds and crash rates. By removing reverse curves and providing wider and separated paths, it also enhances the safety of non-motorized users by increasing pedestrian and bicycle connectivity.

B. State of Good Repair: Addresses current and projected vulnerabilities that, if left unimproved, threaten future transportation network efficiency, mobility of goods or accessibility and mobility of people, or economic growth. The Modified At-Grade Option would replace the existing, deteriorating I-90 viaduct with a new at-grade highway, and will result in lower maintenance costs and reduced vulnerability to deterioration in the future.

C. Economic Impacts, Freight Movement, and Job Creation: Improves system operations, improves multimodal transportation systems that incorporate affordable transportation options such as public transit to improve mobility of people and goods, results in high quality job creation by supporting good-paying jobs, and fosters economic development. The new highway interchange will free up some 75 acres for new ground and air-rights development in one of the largest remaining underdeveloped areas of Boston.

D. Climate Change, Resiliency, and the Environment: Reduces air pollution and greenhouse gas emissions from transportation and results in a modal shift that reduces emissions. The Modified At-Grade Option will reduce congestion associated with the highway interchange, create a new major multimodal transit station, and enhance pedestrian and bicycle connectivity. It also allows for a living shoreline, or other nature-based solutions, to increase climate resiliency, improve habitat for living resources, and enhance active and passive recreation.

E. Equity, Multimodal Options, and Quality of Life: Increases affordable and accessible transportation choices by providing a new major multimodal transit station, enhanced pedestrian and bicycle access to the Charles River basin, new environmental enhancements and noise reduction strategies alongside the Allston and Cambridge sides of the river. The project would reunite two parts of an environmental justice population that has been divided for more than two generations by the original, elevated Turnpike.

F. Innovation: Adopts innovative practices in project delivery and financing by providing for design-build procurement and innovative approaches to highway and transit financing, as well as an ongoing task force of over 50 stakeholders to continue its important advisory role. As residents, business, environmental, institutional, and transportation advocates, we remain deeply invested in this project and know the support of the USDOT’s FY2022 Multimodal Project Discretionary Grant will help move this long awaited project toward construction and completion.

Sincerely,

Douglas Arcand, Allston resident
Jay Arcand & Rita DiGiovanni, Allston business & property owners
Stacey Beuttell, Executive Director, WalkBoston
Rebecca Bowie, President, Cambridgeport Neighborhood Association
Tina Chan, Allston resident
Anthony D’Isidoro, Allston resident; President, Allston Civic Association; MassDOT I-90 Allston Task
Force member
Kendra Foley and Caleb Hurst-Hiller, Interim Co-Presidents, Kendall Square Association
Laura Jasinski, Executive Director, Charles River Conservancy; MassDOT I-90 Allston Task Force
member
Erika Johnson, AICP, LEED AP BD+C, Allston Resident
Jarred Johnson, Executive Director, Transit Matters
Wendy Landman, Senior Policy Advisor, WalkBoston; MassDOT I-90 Allston Task Force member
Anna Leslie, Director, Allston Brighton Health Collaborative
Harry Mattison, Allston resident, MassDOT I-90 Allston Task Force member
Steve Miller, 350 Mass/Cambridge
Galen Mook, Executive Director, MassBike
Josh Ostroff, Interim Director, Transportation for Massachusetts
Deb Pasternak, Chapter Director, Sierra Club of Massachusetts
Cheryl Pavlik, Brighton resident
Jessica Robertson, Allston resident; MassDOT I-90 Allston Task Force member
Staci Rubin, Vice President, Environmental Justice, Conservation Law Foundation
Hazel Ryerson, Allston resident, MassDOT I-90 Allston Task Force member
Stacy Thompson, Executive Director, LivableStreets Alliance
Julia Wallerce, Boston Program Manager, Institute for Transportation & Development Policy
Jack Wofford, Cambridgeport resident; Cambridge Community Representative to MassDOT I-90
Allston Task Force
Becca Wolfson, Executive Director, Boston Cyclist Union
Fred Yalouris, Cambridge Community representative, MassDOT I-90 Allston Task Force
Cathie Zusy, President, Magazine Beach Partners

CC: Jonathan Gulliver, Highway Administrator, MassDOT; The Honorable Michelle Wu, Mayor, City of Boston: Jascha Franklin-Hodge, Chief of Streets, Transportation, and Sanitation, City of Boston: Christopher Coes, Office of the Assistant Secretary for Transportation Policy, USDOT: Paul Baumer, Program Manager, Office of Infrastructure Finance and Innovation, USDOT

Under the US Department of Transportation’s (USDOT) current draft regulations, states won’t be required to distinguish between different roadway users (“motorized” and “non-motorized” users in agency language). That makes for a one-size-fits-all approach, with no room for targeted strategies to improve safety for pedestrians.

Non-motorized fatalities represent 14 – 16 % of national traffic deaths — up from 12 % just a few years ago — an alarming trend hidden in the overall decrease of traffic fatalities.

Until June 9, 2014 USDOT is accepting comments on its current draft of these rules. Tell USDOT to get serious about pedestrian safety; remind Secretary Foxx that not everyone gets lucky like he did (see his quote above).

Smart Growth America has drafted a letter that addresses pedestrians and the need for state accountability on safety – ! 

You can also read our comment letter on USDOT Performance Measures here, or write about the issue in your own words and send a letter to:

Secretary Foxx
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 Comments on USDOT Highway Safety Performance Measures

WalkBoston Comments on USDOT Highway Safety Performance Measures

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

Comments on HSIP National Performance Management Measures

Comments on HSIP National Performance Management Measures

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