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Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011
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Somerville Broadway Streetscape Project, CAPS comments to MassDOT, March 2011

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the Community Access Project sings out the concerns of people with physical and sensory disabilities in these Public Comments to MassDOT. Three recommendations, with photos, are included.

the Community Access Project sings out the concerns of people with physical and sensory disabilities in these Public Comments to MassDOT. Three recommendations, with photos, are included.

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  • 1. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY "The project will reconstruct Broadway from Garfield Avenue to the Boston City Line. Theroadway will be narrowed from four lanes to two lanes with marked bike lanes. The work includes wider sidewalks, pedestrian scale lighting, improved crosswalks with bump outs, bus stops and roadway realignment to create pedestrian activity nodes. Other amenities include bike racks, benches and landscaping."1above: "Road Work Ahead." Broadway near Vinnies and Hathorn St., Somervilleabove: "Where should I wait?" Broadway @ Indiana Ave. bus stop, construction1http://www.mhd.state.ma.us/default.asp?pgid=content/projectsRoot&sid=wrapper&iid=http://www.mhd.state.ma.us//ProjectInfo/ from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 1 of 17
  • 2. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYMarch 16, 2011TO: Frank A. Tramontozzi, P.E.Chief EngineerMassDOT – Highway Division10 Park PlazaBoston, MA 02116-3973cc by email: John Lozada, Director of Civil Rights, MassDOTJohn.Lozada@state.ma.usRE: Somerville- Streetscape Improvements on BroadwayProject Management Section, Project File No. 605219Dear Mr. Tramontozzi and Mr. Lozada,The Community Access Project of Somerville (CAPS) submits written comments for inclusion intothe official transcript regarding the Design Public Hearing for the Somerville- StreetscapeImprovements on Broadway, MA Highway Project 605219, March 3, 2011. Here is offered 3Recommendations, accompanied by photographed examples of concern to our members.CAPS supports the maximum realization of important public benefits from this Project, includingmaximal pedestrian ease of use, public transit wayfinding and improved associated amenities, airquality and other environmental enhancements, and bicycle rights of ways.We give voice to the concerns of stakeholders of any ages and culture living with a broad varietyof disabilities; and, who are often transportation-disadvantaged as a result of poor oversight andnonenforcement of local, State and Federal nondiscrimination laws and regulations, includingarchitectural access code. Currently, this entire corridor represents hazardous, inaccessible andunusable routes and facilities for disabled patrons, personnel, pedestrians and public transit users.It is highly unlikely that people with physical and sensory disabilities felt encouraged to regularlyparticipate at the Public hearings held by the City of Somerville for this Broadway StreetscapeImprovement Project. Please see Appendix One for more information.Thank you for including this written statement and Appendix One, in full and not in part, into theofficial Design Public Hearing transcript. We are grateful for your continued good work andwelcome a written acknowledgement, by email, with any collaborative ideas or questions youmay have. We request notification when the states final Design Plan is completed, and lookforward to sharing this with our affiliates.Sincerely,Eileen Feldman, Project Director, Community Access Project of SomervilleCAPSom@verizon.net from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 2 of 17
  • 3. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYRECOMMENDATION 1: Along this approximately 2800-foot strip of land, there areopportunities to convert this corridor from a motorists pass-through to a destination that offersincreased pedestrian, bicycle- and public-transit options.There are currently multiple hazards for rolling, sensory-impaired and cognitively-impairedpedestrians along this corridor. Yet, in reviewing the documents and plans available for publicinspection for Project File No. 605219, we did not find any evidence that an ADA Transition Plan(such as described within DOJ ADA regulations 28 CFR 35.150(d)(1) & the DOT Section 504regulations 49 CFR 27.11) had been developed for this high-priority TIP2 project.A written ADA/Section 504 plan is necessary prior to the construction phase. Otherwise, theseresources and funds will be disproportionately and wastefully used in ad-hoc decision-making thatwill not result in maximum feasible ADA/Section 504 compliance.In addition, it is important to develop such a coordinated plan prior to the beginning toconstruction, in order to prevent conflicts down the road with other rights of way, utilities,environmental and design considerations.3The City of Somerville needs to develop a written baseline evaluation and ADA/Section 504Transition Plan prior to completion of the Design Phase for this Project.This Plan should thoroughly identify current accessibility and safety barriers; and, make a plan toensure that all maximally feasible accessibility improvements will be implemented during thisProject. There should also be a very clear supervisory plan to ensure that responsible persons areinvolved in an integrated coordination of streetscape safety and access design features with otherenvironmental, design and utilities interests throughout the Construction phase.Suggested considerations 4 :• What real-world wayfinding and orientation problems exist at intersections for pedestrians who are blind or visually impaired?• What usability issues exist at crossings for pedestrians who use wheelchairs and scooters?• How and to what extent can engineers provide comprehensive and cost-effective solutions at intersections that will benefit all intersection users?This ADA/Section 504 Transition Plan should be signed by staff responsible for ADA/Section 504details and made readily accessible and available for public inspection on the City of Somervilleswebsite, along with the updated Final Design Plan, when completed.2 noting TIP Project regs at 23 CFR 450.316(a)3 An example of just such a conflict was described to the community by the DPW Commissionerat a 12/6/10 Somerville Public Safety Committee meeting, regarding the bulb-out that wasconstructed, in 2010, at the School Street bus stop near Market Basket on Somerville Avenue. Thisbulb-out is now a safety and access hazard for all visually-impaired public transit users who willuse that MBTA stop.4 . Thanks to Edward R. Stollof, AICP. See: http://www.ite.org/safety/ITEjournal-wayfinding.htm from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 3 of 17
  • 4. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY SITE PLAN EXAMPLE, RECOMMENDATION 1INDIANA AVENUE- SKEWED CROSSWALK AND COUNTERSLOPED CURB RAMPSIn the only publicly available Site Plan (dated 2/08) we notice that the skewed crosswalk, as wellas the current location for the curbcuts crossing Indiana Avenue is being preserved. Currentconditions at this location thoroughly impede rolling and visually impaired pedestrians.above: Site Plan for this Section, from City website5.Why is the skewed crosswalk being preserved?above photo: site conditions at Indiana Avenue crosswalk during 11/10 construction.5 "entire Proposal" found on the City of Somerville website athttp://www.somervillema.gov/cos_content/documents/EastBroadwayStreetscapeSitePlan.jpg from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 4 of 17
  • 5. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYabove: Measurements at the SE curb cut on Indiana Avenue showed a 11.1% run-slope, with aone-inch transition at the foot of the ramp.Safety concerns with current design of Indiana Avenue crosswalk• This skewed crosswalk and curb cut placement does not provide an accessible route that coincides with the route for the general public.• Blind and visually impaired pedestrians do not have a straight line of travel and are presented with a confusing set of unexpected features, such as a street sign directly across the southern curb cut and a manhole cover directly across from the northern curb cut.• Ramps crossing the curb at a skew can cause wheelchairs to temporarily lose contact with the ground, resulting in tipping and loss of balance accidents.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 5 of 17
  • 6. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYRECOMMENDATION 2: According to the Site Plan, there are approximately 22apartment buildings (16 on west side and 6 on east side) and approximately 70retail, organizational and municipal service public accommodations (40 on westside,and 30 on east side, which includes the Cross Street community center and theEast Somerville Branch Library) along the length of this project.Over 70% of these public services and accommodations are currently not usableby rolling pedestrians right at the entrance. Did the Design Consultants considerquestions of equity and inclusion ? How was feasibility for accessibilityimprovements determined?The Design Plan should include a written component that describes the thresholdfor determining feasibility for the incorporation of maximal accessibility featuresalong the entire length of this project.Accessibility features include any elements, spaces or features that are necessary toprovide essential usability for people of all ages and diverse physical and cognitiveattributes.The maximum public benefits from this Project can be derived if, during the DesignPhase, a detailed analysis is completed regarding how to ensure equity and civilrights benefits for all diverse users--irregardless of whether they were able to "showup" to represent themselves at the public meetings.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 6 of 17
  • 7. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY SITE PLAN EXAMPLE FOR RECOMMENDATION 2FROM HATHORN TO FRANKLIN STREET along BROADWAY- NARROW, CLUTTEREDPEDESTRIAN ZONE and NO ACCESSIBLE OR STREET LEVEL MARKET ENTRANCESIn the Site Plan below, between Hathorn and Franklin, the placement of mailboxes, utility boxesand multiple poles appears preserved, and catch basins relocated, with a widened sidewalk.Some of the markets here have readily removable barriers, with changes in level less than 2 inchesat the entrance.Did the Design Team examine the feasibility of raising the sidewalk along this block, or anywherealong the corridor, to mitigate current barriers to using the stores and other services?Was the feasibility of relocating some of the poles and other street clutter considered, in order toprovide a continuously accessible route and safe wayfinding features?Were bus stop locations considered to ensure safe and accessible waiting areas andmount/dismount access for rolling patrons? from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 7 of 17
  • 8. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYabove: Franklin Street corner at Broadway: Site plan shows that this Bus stop will continue to belocated from just south of the relocated catch basin to mid-block. It also indicates that additionalsidewalk frontage will be added; however the cluttered narrow sidewalk conditions appear toremain unchanged. As we can see, the entrance to Amigos Market is currently a barrier, with achange in level less than 2 inches between sidewalk and door apron. left: Hathorn Street and Broadway: Hathorn is the side street directly south of Franklin and has similar narrow, cluttered site conditions with no street access to markets. from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 8 of 17
  • 9. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYabove: current site conditions around Franklin and Broadway.above: Measurements of curb cut in front of Amigos on southern side of Franklin Street- 14.8%run slope and threshold measures over 1.5 inches. Were baseline curb cut conditions evaluated?How will maximum feasibility for least possible curb cut slopes be evaluated prior to constructionphase of project? from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 9 of 17
  • 10. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAYRECOMMENDATION 3: The City of Somerville has a proven practice ofdisregarding the mandate to provide a reasonably safe, convenient and accessiblepath throughout the limits of the workzone during construction.Please note two dated photos (11/30/10) on the cover page of these comments .Evidence of the routine practice of failing to provide an accessible pedestrian routeduring construction, throughout the recent Somerville Street Reconstruction Project,are seen in five of the six photos on the next page. The sixth photo shows lack ofaccessible route on Washington Street, Somerville, during construction inNovember, 2010.MA DOT and City of Somerville should ensure that a clear agreement is written,prior to the Construction phase of this Project, to ensure that, wherever andwhenever an existing pedestrian route is disrupted by construction activities, thereare proactive and efficient procedures in place to provide a reasonably safe,convenient and accessible path throughout the limits of the workzone during allphases of construction.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 10 of 17
  • 11. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY PHOTOS SHOWING NEED FOR RECOMMENDATION 3Above, left and right photos: Somerville Avenue, August 2008Above left: Somerville Avenue, August, 2009 Above right: Somerville Avenue, Nov., 2009Above left: Somerville Avenue, August 2010 Above right: Washington Ave. at Rose, Nov. 2010from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 11 of 17
  • 12. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY APPENDIX ONE: Streetscape deficiencies surrounding the Cross Street Center, 165 Broadway, Somerville, MA.It is highly unlikely that transportation-disadvantaged residents of Somervilleparticipated in the Public Meetings held by the City of Somerville regarding theBroadway Streetscape Project.Despite a number of sidewalk repairs patched along these routes since 2007, thenumerous streetscape deficiencies were never corrected.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 12 of 17
  • 13. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY Appendix One, continued above: The published Site Plan appears to address some of these deficiencies- and preserve othersfrom: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 13 of 17
  • 14. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY Appendix One, continuedFive public bus routes serve 165 Broadway facility and programs from either side ofBroadway; however, there are numerous pedestrian hazards, especially forambulatory and sensory-impaired residents, on both sides of Broadway and crossingthe side streets. left, google 2009 snapshot, from the North Bus Stop: the bus stop is on the near side, where there is a narrow pedestrian zone because of numerous boxes and poles. At the corner, the apex curb cuts do not serve either crosswalk, left: No curb cut is provided at the other side of Broadways crosswalk, (Taco bell is at the NW corner of Cross St.E.).from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 14 of 17
  • 15. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY Appendix One, continued above: Crossing CrossSt.E from Taco Bell to the Cross St. Center, one encounters numerous utilities and poles and there is not continuously clear pedestrian zone for rolling pedestrians. left photo, Cross St. Center HP spot. The (one) designated HP spot for the Cross Street Center on Cross St.E does not lead to an accessible route, nor is it a van- accessible space.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 15 of 17
  • 16. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY Appendix One, continued left: Minnesota Avenue crosswalk. on SE side of Minnesota Avenue, rolling pedestrians encounter cross slope problems and are not provided an accessible route within the general path of travel. At NW side, the curb cut is too narrow, and the shops active vehicular lot impedes safe travel for all pedestrians.from: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 16 of 17
  • 17. CAPS Public Comments re: MassDOT Project 605219 SOMERVILLE- STREETSCAPE IMPROVEMENTS ON BROADWAY Appendix One, final page SUMMARY image, below: Pedestrian safety and access is impeded, from all directions, surrounding the 165 Broadway Center facilityfrom: COMMUNITY ACCESS PROJECT OF SOMERVILLE March, 2011 Page 17 of 17

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