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

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. The
roadway 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."1

above: "Road Work Ahead." Broadway near Vinnie's and Hathorn St., Somerville

above: "Where should I wait?" Broadway @ Indiana Ave. bus stop, construction

1

http://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

March 16, 2011

TO: Frank A. Tramontozzi, P.E.
Chief Engineer
MassDOT – Highway Division
10 Park Plaza
Boston, MA 02116-3973

cc by email: John Lozada, Director of Civil Rights, MassDOT
John.Lozada@state.ma.us

RE: Somerville- Streetscape Improvements on Broadway
Project Management Section, Project File No. 605219

Dear Mr. Tramontozzi and Mr. Lozada,

The Community Access Project of Somerville (CAPS) submits written comments for inclusion into
the official transcript regarding the Design Public Hearing for the Somerville- Streetscape
Improvements on Broadway, MA Highway Project 605219, March 3, 2011. Here is offered 3
Recommendations, accompanied by photographed examples of concern to our members.

CAPS supports the maximum realization of important public benefits from this Project, including
maximal pedestrian ease of use, public transit wayfinding and improved associated amenities, air
quality 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 variety
of disabilities; and, who are often transportation-disadvantaged as a result of poor oversight and
nonenforcement of local, State and Federal nondiscrimination laws and regulations, including
architectural access code. Currently, this entire corridor represents hazardous, inaccessible and
unusable 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 regularly
participate at the Public hearings held by the City of Somerville for this Broadway Streetscape
Improvement 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 the
official Design Public Hearing transcript. We are grateful for your continued good work and
welcome a written acknowledgement, by email, with any collaborative ideas or questions you
may have. We request notification when the state's final Design Plan is completed, and look
forward to sharing this with our affiliates.

Sincerely,
Eileen Feldman, Project Director, Community Access Project of Somerville
CAPSom@verizon.net


RECOMMENDATION 1: Along this approximately 2800-foot strip of land, there are
opportunities to convert this corridor from a motorists pass-through to a destination that offers
increased pedestrian, bicycle- and public-transit options.

There are currently multiple hazards for rolling, sensory-impaired and cognitively-impaired
pedestrians along this corridor. Yet, in reviewing the documents and plans available for public
inspection 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 504
regulations 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, these
resources and funds will be disproportionately and wastefully used in ad-hoc decision-making that
will not result in maximum feasible ADA/Section 504 compliance.
In addition, it is important to develop such a coordinated plan prior to the beginning to
construction, in order to prevent conflicts down the road with other rights of way, utilities,
environmental and design considerations.3

The City of Somerville needs to develop a written baseline evaluation and ADA/Section 504
Transition 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 to
ensure that all maximally feasible accessibility improvements will be implemented during this
Project. There should also be a very clear supervisory plan to ensure that responsible persons are
involved in an integrated coordination of streetscape safety and access design features with other
environmental, 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 504
details and made readily accessible and available for public inspection on the City of Somerville's
website, 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 Commissioner
at a 12/6/10 Somerville Public Safety Committee meeting, regarding the bulb-out that was
constructed, in 2010, at the School Street bus stop near Market Basket on Somerville Avenue. This
bulb-out is now a safety and access hazard for all visually-impaired public transit users who will
use that MBTA stop.
4
. Thanks to Edward R. Stollof, AICP. See: http://www.ite.org/safety/ITEjournal-wayfinding.htm

SITE PLAN EXAMPLE, RECOMMENDATION 1

INDIANA AVENUE- SKEWED CROSSWALK AND COUNTERSLOPED CURB RAMPS
In the only publicly available Site Plan (dated 2/08) we notice that the skewed crosswalk, as well
as the current location for the curbcuts crossing Indiana Avenue is being preserved. Current
conditions 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 at
http://www.somervillema.gov/cos_content/documents/EastBroadwayStreetscapeSitePlan.jpg


above: Measurements at the SE curb cut on Indiana Avenue showed a 11.1% run-slope, with a
one-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.


RECOMMENDATION 2: According to the Site Plan, there are approximately 22
apartment buildings (16 on west side and 6 on east side) and approximately 70
retail, organizational and municipal service public accommodations (40 on west
side,and 30 on east side, which includes the Cross Street community center and the
East Somerville Branch Library) along the length of this project.

Over 70% of these public services and accommodations are currently not usable
by rolling pedestrians right at the entrance. Did the Design Consultants consider
questions of equity and inclusion ? How was feasibility for accessibility
improvements determined?

The Design Plan should include a written component that describes the threshold
for determining feasibility for the incorporation of maximal accessibility features
along the entire length of this project.

Accessibility features include any elements, spaces or features that are necessary to
provide essential usability for people of all ages and diverse physical and cognitive
attributes.

The maximum public benefits from this Project can be derived if, during the Design
Phase, a detailed analysis is completed regarding how to ensure equity and civil
rights benefits for all diverse users--irregardless of whether they were able to "show
up" to represent themselves at the public meetings.



SITE PLAN EXAMPLE FOR RECOMMENDATION 2

FROM HATHORN TO FRANKLIN STREET along BROADWAY- NARROW, CLUTTERED
PEDESTRIAN ZONE and NO ACCESSIBLE OR STREET LEVEL MARKET ENTRANCES

In the Site Plan below, between Hathorn and Franklin, the placement of mailboxes, utility boxes
and 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 inches
at the entrance.

Did the Design Team examine the feasibility of raising the sidewalk along this block, or anywhere
along 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 to
provide a continuously accessible route and safe wayfinding features?

Were bus stop locations considered to ensure safe and accessible waiting areas and
mount/dismount access for rolling patrons?



above: Franklin Street corner at Broadway: Site plan shows that this Bus stop will continue to be
located from just south of the relocated catch basin to mid-block. It also indicates that additional
sidewalk frontage will be added; however the cluttered narrow sidewalk conditions appear to
remain unchanged. As we can see, the entrance to Amigos Market is currently a barrier, with a
change 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.



above: 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 construction
phase of project?



RECOMMENDATION 3: The City of Somerville has a proven practice of
disregarding the mandate to provide a reasonably safe, convenient and accessible
path 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 route
during 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 of
accessible route on Washington Street, Somerville, during construction in
November, 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 and
whenever an existing pedestrian route is disrupted by construction activities, there
are proactive and efficient procedures in place to provide a reasonably safe,
convenient and accessible path throughout the limits of the workzone during all
phases of construction.



PHOTOS SHOWING NEED FOR RECOMMENDATION 3

Above, left and right photos: Somerville Avenue, August 2008

Above left: Somerville Avenue, August, 2009 Above right: Somerville Avenue, Nov., 2009

Above left: Somerville Avenue, August 2010 Above right: Washington Ave. at Rose, Nov. 2010


APPENDIX ONE:
Streetscape deficiencies surrounding the Cross Street Center,
165 Broadway, Somerville, MA.

It is highly unlikely that transportation-disadvantaged residents of Somerville
participated in the Public Meetings held by the City of Somerville regarding the
Broadway Streetscape Project.

Despite a number of sidewalk repairs patched along these routes since 2007, the
numerous streetscape deficiencies were never corrected.


Appendix One, continued

above: The published Site Plan appears
to address some of these deficiencies- and preserve others


Five public bus routes serve 165 Broadway facility and programs from either side of
Broadway; however, there are numerous pedestrian hazards, especially for
ambulatory and sensory-impaired residents, on both sides of Broadway and crossing
the 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 Broadway's
crosswalk, (Taco bell is at the
NW corner of Cross St.E.).



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.



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 shop's active
vehicular lot impedes safe travel
for all pedestrians.


Appendix One, final page

SUMMARY image, below: Pedestrian safety and access is impeded, from all
directions, surrounding the 165 Broadway Center facility


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

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