August 21, 2018

Chris Osgood, Chief of Streets
Gina Fiandaca, Commissioner of Transportation
Boston City Hall
Boston, MA 02201

Dear Chief Osgood and Commissioner Fiandaca:

WalkBoston is writing with extensive comments on the City’s July 2018 Traffic Signal Operations Design Guidelines. We are glad that this document is getting updated, and especially appreciate the requirement that new traffic signal equipment allow for maximum flexibility for signal phasing.

However, we are concerned that there was no comment and review process for the Guidelines, something that we discussed with BTD staff a number of times over the last several years.

Of even greater concern is the content of the Guidelines – they do not reflect the City’s own Complete Streets Guidelines, its Vision Zero efforts, or the policies and practices set forth in the GoBoston 2030 Action Plan. We also note that there is nothing in the Guidelines about bike signals.

We urge BTD to modify the new Guidelines to reflect the City’s established commitment to walking by making LPIs, No Turn on Red, and automatic WALK the default policy and therefore prioritizing walking in Boston.

As stated in the GoBoston 2030 Action Plan (page 140), the City will take the following approach:

• “Pedestrian-First traffic signals – make walk-signals intuitive and give people walking a head start.”
• “Traffic-signals will…shorten wait times at crossings and make signals adapt in real time to pedestrian behavior and flows”
• “Automatic pedestrian phases – not requiring people to push a button – will be standard”
• “Leading Pedestrian Intervals (LPIs) will allow people to start crossing the street and be seen before cars are permitted to move or turn with a green light”

Our comments below are organized as follows (sorted by section and page of the Guidelines):

1. Areas where we believe that the Guidelines do not set forth best practices and policies and which we urge the City to review and possibly revise;
2. Questions that we have about how the Guidelines will function. In some instances, we have specific recommendations for changes, and in others we look to you for possible solutions.

SECTION: “1. Objective”

1. Page 1: Add an objective to provide consistency among Boston’s signals to the greatest extent feasible. The existing significant inconsistency among intersections causes confusion, reduces compliance by all users, and contributes to unsafe conditions at intersections.
2. Page 1: Add an objective to provide automatic pedestrian WALK recall at all signalized locations, and to eliminate the need for pedestrian recall push buttons from all signals UNLESS they are providing service at very low use intersections or at mid-block crossings that are only activated by a recall button. During the transition period while more intersections are being set to automatic recall, signage/stickers should be provided indicating to pedestrians the hours when the buttons are operable and the hours when automatic recall is operating.
3. Page 1: Add an objective on “Smart Signals.” There is nothing on this topic in these guidelines even though the Boston Planning and Development Agency passed a Smart Utilities Policy in June 2018 that included a section on Adaptive Signal Technology. We suggest adding: “Smart Signals” will not be deployed in the City of Boston unless they can ‘see’ and serve the needs of people walking and biking as well as people in vehicles.

QUESTIONS IN THIS SECTION:
Page 1: The Guidelines state that they will be applied to traffic signals that are “owned and operated” by the City. Will the Guidelines also cover traffic signals owned by others (MassDOT and DCR), but are operated by the City?

SECTION: “3. Traffic Operations Analysis”

QUESTIONS IN THIS SECTION:
Page 2: Traffic Operations Analysis “BTD approved methodology” is referenced. Can you provide a copy of this methodology to WalkBoston, and provide a link in the Guidelines?

Page 2: Are the stated Measures of Effectiveness (MOEs) the correct ones? How were they chosen? Including “95% Vehicles Queues” does not seem like the appropriate metric for multimodal operations as it gives too much priority to vehicle movement. Should the requirement be to look at a multimodal level of service? How will BTD ensure that the needs of pedestrians are always included in the analysis?

SECTION: “4. Operational Considerations”

Overall, LPI+Concurrent WALK should be the default signal guidance. Many of our comments throughout this section propose to flip the stated considerations and default to LPI+Concurrent WALK. FHWA has identified LPIs as proven countermeasures for reducing crashes and improving pedestrian safety.

1. Page 2: (a) & (b) – Operational Considerations should be guided by ensuring pedestrian safety, which can require shorter signal cycle lengths. This may conflict with the stated goal of “maintaining adequate (vehicle) LOS.” We are concerned that striving for a V/C ratio of 0.85 (“D”) during peak hours may have an adverse impact on pedestrians in busy locations both during peak hours and throughout the rest of the day and night.
2. Page 3: (f) “Concurrent WALK should be considered where any of the …” should be replaced with: “Concurrent WALK will be used where any of the …”
3. Page 3: (f) “Leading Pedestrian Interval (LPI) should be considered where any of the following criteria are met” should be replaced with: “Leading Pedestrian Interval (LPI) will be used wherever there are concurrent signals to increase pedestrian safety and provide consistency for all users.”
4. Page 3: LPI+Concurrent WALK should be the default. Bulleted criteria should be edited as shown below:
   • LPI+Concurrent WALK phasing will improve operations (i.e. reduce delays to both vehicles and pedestrians) – Should be replaced with: LPI+Concurrent WALK phasing will improve pedestrian safety; it is an FHWA proven safety countermeasure for reducing crashes.
   • Delete: Conflicting turning vehicle volumes (the sum of left and/or right) are greater than 150. LPI will add safety no matter what the turning volumes are and should not ONLY be used at high volume intersections; consideration should be given to also adding a protected, lagging left or lagging right turn if needed for pedestrian safety.
   • Delete: Pedestrian volumes are high (more than 250 pedestrians crossing per hour in at least one crosswalk). Delete in its entirety, LPI should not ONLY be used at high volume crosswalks. Other cities routinely include LPI at all signalized intersections.
   • Delete: At intersections within”safety zones”… Delete in its entirety, LPI will add safety no matter what the surrounding land uses are and should not ONLY be used at specified intersections.
5. Page 4: Exclusive WALK Guidance – “No Turn on Red restrictions should be considered”– Should be replaced with: “No Turn on Red restrictions must be in place.” If there are exclusive WALK signals pedestrians assume that they are safe to walk and do not need to watch out for turning vehicles. That is the whole idea behind exclusive signal operations.
6. Page 4: (g) Protected or Protected + Permissive left-turn – See question below about lagging lefts. We are not sure how this would affect this guidance, but flag this as needing review.
7. Page 4: (i) No Turn on Red restrictions should be replaced to reflect best practices. As noted in GoBoston 2030, “Since 2010, Washington DC has installed over 160 LPIs at intersections. Anecdotally, DDOT found that these were more effective when used in concert with No Turn on Red restrictions for vehicles.”
8. Page 4: (j) “analyze intersections where APS should be installed.” Should be replaced with: Every intersection that requires signals should have Accessible Pedestrian Signals (APS) added when it is being rebuilt for accessibility. APS push buttons should not be conflated or confused with push buttons for recall for a WALK signal.
9. Page 4: (k) “Pedestrian Recall should be considered…” Should be replaced with: “Pedestrian recall will be the default for all intersections except those with very low pedestrian use.” As noted above, an objective of the signal policy should be to provide automatic pedestrian WALK recall at all signalized locations and to eliminate a requirement for pedestrian push buttons from all signals UNLESS they are providing service at very low use intersections or at mid-block crossings that are only activated by a recall button.

QUESTIONS IN THIS SECTION:
Page 3 (f): It is unclear why “YELLOW TRAP” is listed in the section on LPI+Concurrent WALK phasing. If there is concern about drivers unable to turn left due to large number of pedestrians in crosswalks – a protected, lagging left turn for people driving should be considered. These issues should be given an explanation on Page 4, section (g). We were under the presumption that the City was shifting to lagging left turn arrows to reduce risks for pedestrians and allow additional LPI+concurrent WALK signals, based on the implementation of these measures on Mass Ave throughout the Back Bay. LPI Guidance – revise regarding leading lefts. (See comment directly above). If by “where its operation would have a detrimental effect on other modes of transportation,” the real objective is to allow vehicles to turn, consider having the left turn be a lagging left in order to allow for both movements.

Page 4: (j) the “City’s Accessible Pedestrian Signal Policy” is referenced. Can you provide a copy of this Policy to WalkBoston, and provide a link in the Guidelines?

Page 4: (h) “If a multi-phase pedestrian WALK is the most feasible alternative” is very vague and confusing; what does this refer to? If a multi-phase crossing is thought to be needed due to transit priority, safety for pedestrians, or moving more vehicles through the intersection those tradeoffs and considerations should be indicated.

Page 5: (m) Overnight Flashing Mode Policy – Several serious and fatal crashes (including on Commonwealth Ave in the Back Bay, April 2017, and on Columbus Ave, 2018) – occurred where flashing mode was considered a factor. There was discussion at the Vision Zero Task Force that the City was considering a move away from use of this mode. How were the hours of 3AM to 6AM chosen for this policy?

We look forward to hearing from you soon and working toward revisions that will guide the City toward safer streets.

Best regards,

Wendy Landman, Executive Director
Dorothea Hass, Director of Special Projects
Brendan Kearney, Communications Director

cc
City Council President Andrea Campbell
City Council Planning, Development and Transportation Chair Michelle Wu
City Council Planning, Development and Transportation Vice Chair Frank Baker
Commissioner Emily Shea
Commissioner Kristin McCosh
BTD Director of Engineering John DeBenedictis
BTD Director of Planning Vineet Gupta
Becca Wolfson, Peter Furth, Boston Cyclists Union
Stacy Thompson, Charlie Denison, LivableStreets Alliance
Galen Mook, MassBike