Category: Comment Letter

Comments on 2021 MUTCD Update

Comments on 2021 MUTCD Update

May 14, 2021

Stephanie Pollack, Acting Administrator
Federal Highway Administration
US Department of Transportation
1200 New Jersey Ave S.E.
Washington, DC 20590

RE: WalkBoston Comments on 2021 MUTCD Update

Dear Acting Administrator Pollack:

With this update of the MUTCD, the Federal Highway Administration has an opportunity to overhaul the current standards and create streets that are safe and equitable for vulnerable users, including people walking and biking. WalkBoston endorses the comments by America Walks, NACTO, Transportation for America, and Transportation for Massachusetts (T4MA) that recommend FHWA reframe and rewrite the MUTCD, creating a path for the creation of comprehensive safety-based guidance. Doing so will allow FHWA and the Biden Administration to make strides towards equity and sustainability, while reducing traffic deaths and serious injuries. 

We wanted to highlight a few issues that are of particular importance to people walking:

Accommodating pedestrians and bicyclists through construction work zones is often an afterthought. It is usually handled with pedestrian and bicycle facility closure signs which result in pedestrians and bicyclists experiencing significant out-of-direction travel, insufficient wayfinding for visually impaired pedestrians, or facilities that don’t meet the preconstruction level of multimodal facility accommodation.  

While the current 2009 MUTCD does outline the need to accomodate all modes throughout construction work zones, it fails to provide the same level of specificity and detail that motor vehicle-focused work zone treatments are afforded.  For example, there are only two pedestrian work zone examples (6H- 28/29) which shows a basic sidewalk closure and requirement for pedestrians to reroute around the work zone by crossing the street. Furthermore there are no bicycle work zone examples to draw from. This general lack of detail often results in the design and contractor community either utilizing the facility closure option or in many cases improvising.  

This ongoing update to the MUTCD provides a significant opportunity to bolster the level of design guidance so that the design and contractor community have better examples to draw from that reinforce that need to accomodate a similar level of facility and minimize out-of-direction travel throughout the work zone location.  The State of Vermont (VTrans) and New York City DOT establish good precedent examples for how to best accommodate pedestrians and bicyclists through construction work zones and should be considered as reference documents to be used in elaborating on best practice design guidance within the updated MUTCD.  

Speed limits are still based on the dangerous and disproven 85th percentile rule, and the draft MUTCD does not go far enough to implement the NTSB’s clear recommendation to no longer use this approach. We are grateful that during your term as Secretary of Transportation in Massachusetts, MassDOT started a review of speed setting policies in order to move away from strict reliance on the 85th percentile and take into account other factors, such as land use and the presence of vulnerable road users. We hope that you can bring that experience to inform the MUTCD on speed setting policies.

Outdated signal warrant requirements focus on the history of pedestrian deaths or current crossing demand, instead of known conflicts or planned land use changes. The MUTCD limits the installation of traffic signals because of the potential that they will slow car travel, and as result the guidelines place pedestrians at risk of being injured or killed – before new signals are recommended. We work with many Massachusetts rural villages that need protected crossings on state-owned highways that don’t satisfy the current crossing demand warrant standards. Kids need to walk to school and reach the library without the fear of speeding trucks barreling through the village center.

Pedestrian signal indications are not required at existing or even new traffic signals. We’ve heard from at least one municipality in Massachusetts that the new MUTCD standards will eliminate their ability to show a countdown running through the white man/walk phase, which has meant that going forward they cannot buy countdown units that display the countdown time remaining with people trying to cross the street. This is a change that not only is inconvenient for people walking, but it presents a potential unnecessary cost burden on communities to have to acquire new equipment going forward. We encourage you to ensure pedestrian signals are included at intersections and can display countdown time throughout the pedestrian phase.

Thank you for the opportunity to comment. 

Stacey Beuttell
Executive Director, WalkBoston

WalkBoston Comments on MEPA Regulatory Review 3-31-21

WalkBoston Comments on MEPA Regulatory Review 3-31-21

March 31, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs

Attn: MEPA-regs@mass.gov Dear Secretary Theoharides:

WalkBoston appreciates the opportunity to provide comments on the MEPA Regulatory Review effort. As you are aware, we frequently provide comments on projects that are submitted for MEPA review and feel that this step in the Massachusetts regulatory system is vital for maintaining the quality of the environment in the state, and that issues are often surfaced that result in project changes that are beneficial in many areas of environmental quality.

Our comments on the regulations themselves are focused on the transportation requirements of the process. For clarity, where we have pasted text directly from the MEPA forms or regulations the text is shown highlighted in a text box.

Project Notification Form (Page 2)

Summary of Project Size Existing Change Total & Environmental Impacts

Vehicle trips per day Parking spaces


We suggest that the summary table be modified to reflect all modes of travel to ensure that project proponents and all reviewers are thinking about the range of transportation demands that projects will generate. In turn, as discussed later in this letter, the review thresholds should be redefined to include transit trips as well as vehicle trips and parking spaces.

This will also address the issue that, in asking for Vehicle trips per day (based on the ITE Trip Generation Manual), the availability and use of other non-auto modes of transportation, including car-pooling/ride-sharing, transit, walking and biking, is not acknowledged or included quantitatively in the PNF. By “adjusting” the ITE trips, all person trips (i.e. the total demand for travel) are accounted for.

Further, we suggest that the form should also ask for peak hour vehicle and transit trips, as in some locations peak hour trips are a better indication of impact than daily trips. We understand that this may require some new modeling tools that make better estimates of non-vehicle trips, but we believe that this is an appropriate step for Massachusetts to be taking with respect to transportation thinking. The reporting of trip generation in the ENF table should include the following:


  1. Daily Vehicle trips
  2. Peak Hour* Vehicle trips
  3. Daily Transit trips
  4. Peak Hour* Transit trips
  5. Daily Walking trips
  6. Daily Bicycle trips
  7. Parking spaces

* Typically, the peak hours would be weekday commuter peaks but can include other periods or weekends for some land uses such as Retail, Recreation, Entertainment etc.

(Page 16)


Please delete the qualification phrase “Traffic Generation” from the title – this section is about all transportation modes.

We recommend deleting this question as a threshold question. If a project does not require state permits, but does meet the review thresholds due to the numbers of vehicle trips and transit trips, the proponent should still be required to complete the traffic multi-modal transportation impact questions on the form. The environmental impacts of the transportation demands generated by the project do not disappear if no state permits related to state-controlled roadways are required.

II. Traffic Impacts and Permits

Title – replace “Traffic” with “Transportation” to encompass all transportation modes.

Question identification – please correct the lettering system so that there is only one question per letter. The questions are presently shown as A, B, C, D, C, D, E.

I. Thresholds / Permit

B. Does the project require any state permits related to state-controlled roadways? ___ Yes ___ No; if yes, specify which permit:


A. Describe existing and proposed vehicular traffic generated by activities at the project site:

Number of parking spaces Number of vehicle trips per day ITE Land Use Code(s):

Existing _______ ________ ________

Change ________ ________ ________

serving the site? Change


T otal _______ ________ ________

T otal ________ ________ ________

B. What is the estimated average daily traffic on roadways

1. ___________________

2. ____________________ 3. ____________________

Existing ________ ________ ________

C. If applicable, describe proposed mitigation measures on state-controlled roadways that the project proponent will implement:

D. How will the project implement and/or promote the use of transit, pedestrian and bicycle faciliti and services to provide access to and from the project site?

The table in Section A should be modified to include daily transit as well as vehicle trips, and peak hour trips by vehicles and transit. The peak hour trips should be appropriate for the land use of the project (e.g. M-F commuting for office use, and Saturday for retail, etc.).

While daily vehicle and transit trips are useful proxies for the scale of transportation impacts and as general thresholds, we believe that projected peak hour trips are a better indicator of potential impacts by each mode. We suggest therefore that the impacts called for in Section B should be based on peak hour trips assigned to the roadway network and the transit network.

Similarly, we suggest that Section C should be modified to include proposed mitigation measures on all transportation infrastructure that the project proponent will implement.

Please add detail to Section D on transit, walking and biking – for example by adding the following questions.

  • –  Are sidewalks provided along all road frontages of the project?
  • –  Are sidewalks provided along all roadways within the project site?
  • –  Are bike facilities provided on all of the roads around the site?
  • –  Are bike facilities provided on all of the roads within the site?
  • –  Provide a map showing where the nearest transit facilities are provided.
  • –  Are sidewalks and bike facilities available to get to the nearest transit?
  • –  Do sidewalks within the project site connect to the local sidewalk/trail network or

    other sidewalks?


(Page 17)


We suggest that the title be changed to “TRANSPORTATION SECTION (for Transportation Infrastructure Projects” to clarify the purpose of this section and the need to complete it.

Section 11.03 Review Thresholds, (6) Transportation

We urge that MEPA review the 3,000 adt threshold in order to look at two questions, both of which we believe are important to understanding how projects will affect the multi-modal transportation systems into which they fit.

  1. (1)  We believe that the threshold should include both vehicle and transit trips/day to reflect the importance of transit trips to the functioning of Massachusetts’ transportation systems. Congestion and capacity on some portions of our transit system are of greater importance than roadway congestion and capacity, so we urge that it be measured and included as a threshold. Further, the first or last part of a transit trips involves walking to arrive at, or depart from, a development, and are therefore important in considering the adequacy of the pedestrian infrastructure supporting the project.
  2. (2)  Is 3,000 the appropriate number of vehicle and transit trips generated that cause such a small impact on area transportation conditions that review beyond an ENF is not needed? Or, have conditions changed since that threshold was established (greater levels of development, greater awareness of the impacts of traffic on human health, water quality etc.) that a lower threshold should be established?

The number of parking spaces included in a project is a proxy for many potential impacts on the environment including transportation, use of land (about 8 acres of paving would be required for a 1,000-car surface parking lot), water quality, habitat, and others.

(a) ENF and Mandatory EIR.

6. Generation of 3,000 or more New adt on roadways providing access to a single

(a) ENF and Mandatory EIR.

7. Construction of 1,000 or more New parking spaces at a single location.


We recommend reducing the threshold for parking spaces to 500 spaces which still represents a very significant impact that should be reviewed in full through an EIR.

As a result of the new climate bill signed by Governor Baker this week, we will be looking to EEA and MEPA (and others) for guidance on how the new Climate Bill environmental justice requirements will address cumulative transportation impacts and not simply the new impacts that result from an individual project. We believe that the guidance may require significantly greater review of both impacts and mitigation measures.

Thank you for the opportunity to comment on these important regulations. We would be pleased to speak with the MEPA staff if they have any questions about our comments.

Best regards,

Stacey Beuttell, Executive Director
Wendy Landman, Senior Policy Advisor

Shattuck Campus Redevelopment at Morton Street Proposal Comment Letter

Shattuck Campus Redevelopment at Morton Street Proposal Comment Letter

April 23, 2021

Loryn Sheffner, DCAMM
1 Ashburton Place, Suite 107 Boston, MA 02108

Re: Shattuck Campus Redevelopment at Morton Street Proposal

Dear Loryn,

Thank you for the opportunity to comment on the Shattuck Campus Redevelopment Proposal. If the 13-acre Shattuck Campus site will be redeveloped for public health purposes, we hope the project will address connections to and along Morton Street to make it safer and more convenient for pedestrians, and reconnect Franklin Park to this side of the neighborhood. We suggest that the housing development plan, if adopted, include an enforceable requirement of wide, accessible walking paths and tree canopy in the spirit of the Olmsted Plan.

One of the high level planning principles identified is to “improve access to neighborhoods with public transit, bike and pedestrian options.” This project, in conjunction with the greater Franklin Park Action Plan, has the potential to more deliberately restore public access to the park from the Morton Street side. The state needs to think beyond the borders of the project bounds in order to make this happen.

While Morton Street is a MassDOT road, two of the roads that feed into it with similar cross sections, American Legion Highway and Blue Hill Avenue, are listed on the City of Boston’s High Crash Network in the top 3% of streets for motor vehicle crashes. The high speed design of Morton Street impacts all other modes. It feels uncomfortable and is an unpleasant walking and biking environment; there are sections of the street that do not have sidewalks on either side. The bus stop on Morton Street to access the Shattuck site was made accessible in the last few years by removing the center median barrier and adding curb ramps, yet the existing unsignalized crossing of multiple vehicle lanes is still dangerous for people walking. The project site is not far from the Forest Hills MBTA station, yet seems much further since Morton Street is poorly designed at this point for walking.

We hope that there will be a collaborative focus on traffic calming beyond the immediate project footprint incorporated into this redevelopment project and adjacent park effort by DCAMM, MassDOT, and the City of Boston.


Brendan Kearney, Deputy Director

North End Cross Street Boutique Hotel Comment Letter

North End Cross Street Boutique Hotel Comment Letter

Lance Campbell
Senior Project Manager
Boston Planning & Development Agency
April 19, 2021

Re: WalkBoston Comments on North End Cross Street Boutique Hotel

Dear Lance:
WalkBoston attended the public meeting on April 7th for the North End Cross Street Boutique Hotel and offered comments during the virtual meeting. We are pleased that many of the changes will improve the pedestrian experience in approaching and using the proposed buildings, as well as the newly created plaza and passageway.

The passageway between the two buildings will create a new connection between the Rose Kennedy Greenway and Cutillo Park for people walking. We are glad to see the plan will activate the plaza for people along the Greenway, as it includes new seating opportunities both bordering the building with the hotel and restaurant spaces, as well as new public seating closer to the corner of Hanover Street. We appreciate the visual cue of the concrete sidewalk through the site plan’s plaza as recommended by the City of Boston’s Disability Commission.

The Cross Street and Hanover Street intersection is currently used as a geofenced rideshare pickup and drop-off location, as users are directed within their apps to meet their drivers here. This geofencing makes it possible to limit rideshare pickup and drop-off on other streets in the North End, and is one way that the City of Boston can regulate curb use. With an improved pick up and drop-off area included in this project, we hope that this effort will continue.
Finally, we ask that the proponent commit to clearing the entire plaza and crosswalks curb cuts of snow and ice during the winter months in order to ensure safe walking throughout the year. Thank you for the opportunity to comment on the plan. We would be pleased to discuss any of these items further with you.

Thank you,
Stacey Beuttell
Executive Director, WalkBoston

Brendan Kearney
Deputy Director, WalkBoston

76 Ashford Street Comment Letter

76 Ashford Street Comment Letter

April 23, 2021

Michael Sinatra
Boston Planning and Development Agency

Re: 76 Ashford Street PNF

Dear Mr. Sinatra:

WalkBoston has reviewed the PNF for the 76 Ashford Street Project with respect to its impacts and benefits for people walking and using transit.

We are very pleased that the proponent is reserving the land and right-of-way necessary to provide walking, biking and bus access to West Station, and that the built condition will be at the elevation necessary for this connection. This is an absolutely critical element of a successful multi-modal West Station that will allow this part of Boston to become home to transit oriented development. We request that the City make this reservation for walking, biking and bus access to West Station a requirement for the project to receive its environmental and development approvals.

We support the interim use of this access reservation land as open space and urge the proponent to work with the City of Boston, MassDOT and the MBTA to ensure that once the I-90 Allston Multi-Modal Project is built that residents of the building will have access to high quality open space in the neighborhood and along the Charles River.

The building ground-level retail space which will face West Station is a welcoming element of the project to transit users and people walking, and is an appropriate and welcome project element.

We are also pleased that the project has been proposed with a low ratio of parking spaces (approximately .25 spaces/unit). We believe that this is appropriate for a development that will be in such close proximity to West Station and that is also well served by existing bus and Green Line service.

Overall, we are excited that the private development community is responsive to the promise of West Station and its potential for excellent transit service, and look forward to seeing a transit oriented development that includes on-site affordable units.

Thank you for the opportunity to provide comments.


Wendy Landman, Senior Policy Advisor