October 16, 2018

Secretary Stephanie Pollack
Massachusetts Department of Transportation
10 Park Plaza
Boston, MA 02116

Dear Secretary Pollack:

WalkBoston is pleased to provide comments on the Draft MA Pedestrian Transportation Plan, and to see so many of the comments that we and other members of the Massachusetts Bicycle and Pedestrian Advisory Board captured in the Plan.

The vision, goals and principles set a strong context and base for the Plan, and we are especially pleased that MassDOT has adopted the principle of leading by example and supporting municipalities. As the largest single investor in the State’s roadway and pedestrian system, MassDOT has a critical responsibility to take pedestrian safety, accessibility and convenience seriously in all of its actions and investments.

We specifically applaud several of the action items including:

• 3-3: Research on benefits and impacts of automated speed enforcement (ASE). We will continue to advocate for legislation that will allow ASE to be is implemented in an equitable manner. Automated enforcement has been shown to be an effective means of discouraging dangerous driver behavior.
• 4-1: Construct safe crossings to connect bus stops to destinations, starting with MassDOT-owned corridors.
• 5-1: 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.
• 6-1 – 6-3: Collecting and analyzing pedestrian focused data.

Our comments below reflect several additional issues and refinements that we believe will strengthen the Plan:

1. The equity discussion should be updated to include MA Department of Public Health (DPH) injury data for Massachusetts which reveals substantial differences in injury rates by race. Under Initiative 2 we recommend adding an action item of preparing in-depth analysis of injury patterns across the state that combines the crash reporting provided by police and EMS and the hospital data that is gathered by DPH. We understand that MassDOT and DPH have begun this analysis, and think that this process should be formalized as one basis for the prioritization analysis.
2. Initiative 1 sets ambitious and strong actions for MassDOT’s own design and operations practices, including maintaining pedestrian routes through work sites during construction. We are concerned that Action 1-1 will be difficult to accomplish and measure without outside review, and suggest adding a measure for tracking progress such as the following:
   • Create an annual review process of MassDOT development, scoping, scoring, design and construction that invites advocates and peers from outside the agency to comment on how pedestrians have been prioritized in agency activities. The review should be designed to guide MassDOT in a continuous improvement process to learn from each project:
     • What is working well?
     • What can be improved?
3. Initiative 5 of the Plan should include specific reference to traffic signals, including a measure that tracks the number of signals on MassDOT roads that include pedestrian-focused attributes, such as concurrent WALK signals, Leading Pedestrian Intervals (LPI), and automatic recall of WALK signals (not requiring people walking to push a button). In addition, MassDOT should consider providing more in-depth guidance to municipalities about good practice for pedestrian signals – the inconsistency in signals among the State’s 351 cities and towns contributes to confusion for pedestrians and drivers which can lead to unsafe conditions. This section may also be an opportunity to share information on the safety benefit for “No Right Turn on Red.”
4. Principle 3 of the plan describes that MassDOT will lead by example yet municipalities are critical to the success of the plan, since MassDOT owns just 8% of all sidewalk and 8.2% of all roadway miles in Massachusetts. We encourage MassDOT to add information about that other state agencies that maintain pedestrian facilities, like DCR and the MBTA, and should recommend that they also follow MassDOT’s best practices for communities to emulate.
5. The presentation of the report was visually pleasing, but has some features that could be improved:
   • If using this web-based ARCGIS format for any future reports, please create a way to easily jump to sections within the document from the introduction. The table of contents is a static list, which makes it difficult to refer back to specific sections since page numbers are not obvious.
   • Using the share link at the top left of the page re-directs a user back to the beginning of the document, not to the page/section of the document that the user is on. There was not a readily apparent way to link to a section.
   • While this web-based ARCGIS report format allows a user to zoom in on statewide maps (which likely would be rendered difficult to read in a printed format), please provide an option to access the final version of the plan in a visually clear PDF form.

Thank you for the opportunity to provide comment.

Sincerely,

Wendy Landman
Executive Director