Hearing about the Route 38 Hearing

To follow up on our previous posts, I attended last week’s public hearing on the Route 38 project near Kittredge Park. Its purpose, in MassDOT’s words:

As part of the design process for this project, we are conducting this public hearing to explain the proposed improvements, listen to your comments and answer any questions you may have. At the conclusion of the hearing, MassDOT will review all of your comments and, where feasible, incorporate them into the design of the project.

Wait, first, what exactly is MassDOT’s Public Process?

Under state and federal law, the state has to allow citizens to comment on projects. I’ve looked into this a bit to try to figure out how the process works, so I’ll spend a little time on that here.  MassDOT’s guiding documents do put an emphasis on public participation. Their 2014 Public Participation Plan lists their values related to participation: Dedication, Respect, Innovation, Diversity, and Honesty (accuracy, understandability, and accessibility).

A project’s public life begins when it’s first put on the “Transportation Improvement Plan” or “TIP” before design begins. The Nesmith Street project was put onto the TIP because of a Road Safety Audit conducted in 2010. The regional planning agency annually requests comment about the TIP at meetings around Greater Lowell, reaching out through traditional media and email lists. I’ve heard mostly only people very interested in the transportation system—transportation planners and public officials—comment on the TIP. In fact, even though the Route 38 project was on the TIP, one public meeting participant asked why he had only heard of the project recently, from the Sun article.

The “Public Hearing” was another step of that public process. When a project has completed its environmental process, right before MassDOT formally accepts the preliminary design that will be developed into the final design, it holds a formal meeting to allow citizens to get their comments on the record. The way they conduct this review is highly regulated, including notice requirements and accessibility. A list of everything they have to consider is here. This is the last time for formal public participation, unless the project gets delayed or they encounter unforeseen environmental complications. I learned a lot about their process by reading Chapter 2 of their guide.

What happens at a session like this? They show their plans, which are 25% complete. This part of the meeting is both very detailed and lacking some of the most relevant information. I often struggled to follow what was being discussed, to see what was being discussed on the slide, and to understand the values that were being promoted. Other participants expressed confusion, too. I appreciate that they were willing to share their plans online (which surely should be standard) because it allowed a little more time to digest.

Nesmith Street Plan

This is an image of their plan for Nesmith Street. Grey is road widening, brown is sidewalks, and yellow is new greenspace. The City engineers put together a great Route 38 project website with all their materials here.

What was MassDOT’s presentation about Nesmith?

After a brief introduction by MassDOT, their consultant from Bayside Engineering then spoke about the project, which includes five intersections. In addition to the ones I’ve written about on Learning Lowell before (Nesmith/Merrimack and Nesmith/Andover), they are putting in new signals at Nesmith/Stackpole so they can be coordinated with the other signals; and they are doing a realignment and signal improvements at the intersection of the Route 38 highway at Boylston/Fairmount and Douglas/Phoenix.

Almost all the participants were interested in the Nesmith Street work, and that’s where the engineers spent most of their presentation. The consultant engineer presented several alternatives they had considered, then showed the audience which alternative had already been chosen.

There were several things common to all alternatives:

  • The outside edges of the sidewalks would stay in the same place, meaning only the sidewalks and what’s between them would change.
  • The project would improve crosswalks at both intersections, including handicap ramps.
  • It would make the signals a pedestrian-only phase, meaning people have to press a button and wait for the light to go through its cycle, but then all the lights will be red to make people crossing the road safer.
  • Finally, the project would make two of the curves between Andover and Nesmith a little more “square.” This will make cars turning onto Nesmith go just a little more slowly.

These changes were supported by the participants at the meeting. The differences between the alternatives? Whether they make Nesmith wider or not.

This leads to the big question: do the trees have to go? Does the road have to get wider? According to them, absolutely yes. The details for why are easily obscured by technical details, but I’ll do my best. They considered 4 options that save the trees and one that widened the road. The differences between the 4 options were which ways the lanes would go.

Five very simple diagrams of the options shown at MassDOT presentation

This is a simplified drawing I did to try to understand the different options, showing the direction traffic would go in each direction, with Andover Street being at the bottom and Merrimack being at the top. The numbers over each drawing are how wide the road would be, including lanes and shoulders. Option 4 is just keeping it the way it is, and option 5 has a left-turn lane that starts in the middle going in either direction.

Nesmith Street

The plan would remove the trees between road and sidewalk on both sides, resulting in 12 trees total removed.

Option 3 is the widened road. It would keep the 5’ sidewalk on the Kittredge Park side, but that sidewalk would have signs and electric poles added to it. The sidewalk would be on top of a retaining wall that would be almost 4’ at its tallest, but an average closer to 2’. The retaining wall would be stone masonry and have a decorative railing. The sidewalk on the other side would be narrowed to 5’, requiring removal of three additional trees. This is in the plans, but they did not mention this out loud, and I didn’t understand it until I was able to look at the plans online. I wonder how many people in the room did.

Modeling Traffic

The engineer did an analysis of each option, giving a letter grade that represents how long people would have to wait during morning and evening rush hour at each intersection. They also showed how long their model thinks cars would back up before each light turns green during rush hour.

Their model, which is set in the year 2024 and assumes that traffic will increase for the next ten years, showed that all the options would cause traffic to back up from Merrimack past Andover or vice-versa, but that the 4-lane option would cause the least amount (in evening rush hour, the traffic would back up from Merrimack to just past Andover). However, I’m still not sure how they figured that out, and just how bad traffic would be under options 1 or 2. It would be nice to understand better what they presented, because it’s so hard to know whether they’re hearing our values as they build their models.

Option 3 PM Queue Analysis Nesmith Street

This is an example of the “queue analysis” they showed us. The red and yellow lines represent how far they think cars will back up during a red light. All the analyses are on the city’s website.

Those models are worth talking about a little bit. They’re based on ever growing traffic numbers, which if they continue, would result in losing any gains over time as the number of cars on the road continues to grow with Boston’s sprawl. This goes to MassDOT’s overall focus: their concerns are at the state level. To them this is a state highway, not a neighborhood road.

Categorizing Roads

When they opened up for comments, someone asked why the neighborhood should have to bear the brunt of all this traffic. The answer was, in essence, because that’s the way it is.

State legislation in the 1990s mandated a process to classify roads—this is called “Functional Classification”. MassDOT worked with regional agencies to define every Massachusetts road into one of three nationally-understood categories: Arterials, Collectors, and Local Roadways. Nesmith Street was classified as an Arterial. According to MassDOT, “These roadways provide the highest level of mobility at the greatest vehicular speeds for the longest uninterrupted distances. Generally, these roadways provide connections between Massachusetts cities, metropolitan regions, and bordering states…”

The categories are further sub-divided based on whether they’re urban or rural, and whether they’re limited-access, major, or minor. The category of a road changes what design it gets. For example, the MassDOT Design Guide states that designers should try to put a minimum of 4’ shoulders in urban arterials and 11’ lanes in urban arterials. Local roads can be narrower. Whenever designers go beyond minimums or maximums, they have to get permission from a “Design Exception Committee” and the Federal Highway Administration if they’re getting federal funding.

It’s a deliberately difficult process to get roads recategorized. A town that wants to change the category of a road has to prove that land use and traffic patterns have changed, and the road is no longer used for travel between cities. It’s a reinforcing cycle: cars use a certain road to get between cities, and that road gets categorized as an arterial, and then local and state engineers design it to be easier to use as an arterial, then more cars use it to get between cities.

When asked about this, the MassDOT engineeres replied that there are only so many paths over the river into New Hampshire. Any path is going to be full of traffic. The neighborhood just has to accept it. Our local engineers did mention that because traffic is bad on Nesmith, cars are going on other local roads like East Merrimack. The engineers’ goal is to minimize the amount of traffic on roads that aren’t arterials.

Map with cut-throughs around Nesmith

A drawing I did showing some ways cars avoid Nesmith, cutting through other neighborhood roads

It’s really important to note that the engineer said they would not consider lanes narrower than 11’ and even called 11’ lanes “nice and tight”. According to the MassDOT design guide, lanes between 11’ and 12’ should be used for speeds above 45 MPH, traffic above 2,000 vehicles per day, or trucks and busses more than 30 per hour. Traffic on Nesmith is above 30,000 vehicles per day.

However, not everyone agrees that 11’ lanes are ideal in urban settings, even with high traffic volumes. The National Association of City Transportation Officials’ guide recommends 10’ lanes in all but special circumstances, and Chapter 5 of the MassDOT guide itself mentions that 10’ lanes can be used in areas of limited right-of-way to provide greater separation between vehicles and pedestrians.

What did the neighborhood have to say?

There were about 30-40 residents in attendance, and perhaps a dozen spoke. MassDOT let city officials speak first, and city engineers read a letter from the City Manager supporting the project during the time. The meeting went late, after 9:00 pm, and many residents left before they had a chance to speak. However, the library was kind enough to stay open that everyone who waited could have their say.

There were concerns big and small. Nobody commented that they thought making the road wider was a good idea. Many liked the idea of better timed lights and pedestrian crossings, as well as clearer lane markings. Lots of people were disappointed in the potential loss of the trees, and many were worried about traffic speeding up and getting noisier. Nobody was excited about a long and disruptive traffic project. Some had more specific concerns, such as the design of the retaining wall or the accommodation of bicycles.

One participant asked whether MassDOT or the City was thinking about the entire road system holistically and the problem of there being not enough routes for cars travelling through (not to) Lowell, and the city engineers said that it was a problem faced by all communities, not just Lowell, and that, “We’re working on it.” Jane Calvin argued that the health of trees, or that the wrong type of trees were planted, should never be an argument to remove a tree planting strip, as that can be fixed without removing the strip. She also pointed to a City ordinance that said that the City would need to replace each tree they cut down with an equivalent tree or trees elsewhere. The Sun wrote up a great story about it, talking about both sides’ positions.

Does the fact that a dozen residents voiced concerns matter? Probably not. I have to be honest with this post: it’s very likely that there’s very little that can be done about this situation. While MassDOT is fulfilling its legal obligation to show us their plans, they have very little motivation to change them at this point. When people voiced concerns, they generally defended their existing design. For example, they showed a picture of the least healthy tree in the area when talking about the trees, and they said they believed the retaining wall would serve a similar traffic calming function.

They’ve spent a lot of time on this getting it the way they think it should be, and hearing residents say “we think it will be less safe” isn’t going to change an expert’s mind. They’re committed professionals, of course they believe in what they’re presenting. It would take a massive pushback, universal and noisy, and including our state representatives to alter the course of things now.

Should we try? I think so. This isn’t the engineers’ and planners’ fault. They work with the information they have, and with the parameters they’ve been given. Chris works with the city folks that helped in this process, and they’re good people, working every day to build a better Lowell for everyone. They were eager to offer to explain the process to residents with detailed questions, and they even offered to meet with residents to do a walk-through of the area in question. It’s not helpful to frame city or state folks as villains. They’re convinced based on their research that this is the best course of action for the greatest number.

If we’re going to build a Lowell where trees and pedestrians matter as much as cars, they’re going to have to hear from us as a community that these things matter to us, and they’re going to have to hear it a lot. They hear a lot of complaints from drivers! We will probably lose some of these debates along the way, unfortunately. But sea change is possible, even if it takes longer than we want it to.

How to Comment

The last day to send comments to MassDOT is 10 days from the hearing date, so that means any comments must be postmarked by this Wednesday! If you want to sign the petition to save the trees, click on this link and do it by Tuesday before 3:00 pm, when it will be mailed to MassDOT. Here’s the full info:

Written statements and other exhibits in place of, or in addition to, oral statements made at the Public Hearing regarding the proposed undertaking are to be submitted to Patricia A. Leavenworth, P.E., Chief Engineer, MassDOT, 10 Park Plaza, Boston, MA 02116, Attention: Roadway Project Management, Project File No. 606189. Such submissions will also be accepted at the hearing. Mailed statements and exhibits intended for inclusion in the public hearing transcript must be postmarked within ten (10) business days of this Public Hearing. Project inquiries may be emailed to dot.feedback.highway@state.ma.us.

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One thought on “Hearing about the Route 38 Hearing

  1. Excellent detailed work, Aurora, thank you for your efforts. When we look at the larger picture, though, I’m bothered that the only solution MassDOT seems to have for Boston’s inevitable sprawl is to build, what looks like me, highways through our neighborhoods. Why is the focus for the future on accommodating more car volume rather than creating a robust public transit system?

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