The Minnesota Department of Public Transportation has released a draft of its new five-year Strategic Highway Safety Plan (SHSP) at http://www.dot.state.mn.us/safetyplan/pdf/2014_SHSP_060914.pdf
I encourage people to read the plan and comment on it.
The public only has until July 8 to make comments. Comments should be sent to email@example.com
Below are my own comments. They’re super wonky but so are safety plans.
Motorized vs. Non-motorized Safety
The Draft Minnesota Strategic Highway Safety Plan (SHSP) fails to give adequate focus and attention to bicycle and pedestrian crashes with motor vehicles.
In the first paragraph of its executive summary, the Draft Plan claims that “It describes how many, where, what type and to whom crashes occur.” In reality, at least as it applies to bicyclists and pedestrians, its data is shoddy and incomplete. As such, its recommendations are inadequate and potentially counterproductive.
If we are to reduce injuries and deaths, we have to rely on at least four “E”s—evaluation, engineering, enforcement and education. If the data collection and “evaluation” of that data is inaccurate, then the remaining E’s will be inaccurate as well and the plan will be a failure.
The SHSP focuses overwhelmingly on motor vehicle crashes. It measures “success” of the “Towards Zero Deaths” (TZD) program in “Traffic fatalities and serious injuries per 100 million vehicle miles traveled.” It doesn’t measure success in bicycle/pedestrian crashes, bike/pedestrian access to public streets and roadways, or the number of bike/walk trips taken. As such, it has a myopically car-centric view of “safety.”
Data Collection is the Key
With bicycles and pedestrians, the SHSP suffers from poor data collection and poor evaluation. It fails to consider many easy, obvious internal agency strategies for reducing bike/ped crashes, and fails to set specific targets, either for bike/ped crash reduction or for spending money in a way that will bring about reductions. The plan blames public attitudes around traffic safety that “do not yet reflect a culture that finds traffic fatalities as unacceptable.”
Yet, with bicycle and pedestrian injuries and fatalities, it is often MnDOT and its partner agencies themselves (not the public) that are the major stumbling block to increasing safety. These agencies are unwilling to do the evaluation, engineering, enforcement, education and spending that is necessary to create a safer bicycle and pedestrian environment on public streets and roadways.
Right from the beginning, the safety plan fails to single out pedestrian and bicyclist injuries and deaths caused by motor vehicles. In it’s “Key Minnesota Traffic Safety Laws” it fails to mention two that are especially important to cyclists and pedestrians:
1. That motor vehicles are supposed to maintain a three foot passing distance when going around bicyclists and
2. That motor vehicles are required to stop for pedestrians attempting to cross a street, even (and especially) at unsignalized intersections.
Do questions about these two laws even exist on the state’s driving test? If so, how many people taking the test get them wrong (as a percentage of all test takers)?
The plan doesn’t look at the state driver’s examination as a possible education tool or source of data as to which safe driving practices drivers are or are not learning. It also fails to look at ways that MnDOT and its partners can improve safety and change the state’s driving culture by taking internal agency actions.
For example, in the Twin Cities, I see lots of police and public agency employees (in agency vehicles) ignore pedestrians, drive while texting or on their phones, and drive recklessly. I personally know two people who’ve been hit by ambulances and one person hit by a police car. If every employee at MnDOT and its partner public works, public safety and law enforcement departments committed to stopping for pedestrians at uncontrolled intersections and passing cyclists with at least 3 feet of passing distance, as well as not driving while texting or using cell phones, it would undoubtedly reduce motor vehicle crashes with bicycles and pedestrians and it would set an example for the rest of Minnesota’s drivers. Such an idea or any evaluation or reevaluation of state agencies’ own internal policies is not considered. This extends to evaluating current engineering practices, a point I will get to later.
The Language of Safety
The plan’s language and data overwhelmingly focuses on deaths rather than the total number of “crashes.” As such, it fails to question what portion of the recent decline in deaths is due to more sophisticated life-saving procedures on the part of hospitals and first responders and what portion is due to better evaluation, engineering, education or enforcement.
The plan claims that “The Minnesota Department of Public Safety maintains crash records and annually publishes Minnesota Motor Vehicle Crash Facts to provide a summary of statistical information about the crashes.” Perhaps this is true on MnDOT roadways and trunk highways, but, in the City of Saint Paul, there is no systematic collection of bicycle and pedestrian crash data available to the public.
The Saint Paul Bicycle Coalition has been told by the city’s Public Safety Department that they lack the staff to even collect bike/ped crash data (as separate from car-to-car crash data) and they are not currently publishing it (if they ever did). We asked if we could get access to it ourselves to glean important information and were told that for reasons of HIPAA laws, only public safety staff can access it. One year (2008) an effort was made to get that year’s citywide bike and pedestrian crashes tallied and mapped but I know of no other year in which that has occurred. Certainly there is no public website on which this data is available.
A majority of bicycle and pedestrian crashes with cars occur in cities and towns. If you have the second most populace city in Minnesota not collecting data, then your agency knows far too little about what is happening with bicycle and pedestrian safety on a statewide level. I’m guessing that Saint Paul is not the only city or town in Minnesota that fails to collect bicycle and pedestrian crash data and provide it to the public. So the plan needs to make as its top priority actual data collection and making that data public, where it can be analyzed by NGOs, academics, stakeholders and others who can contribute to the safety conversation.
According to the SHSP’s “Table 2”, pedestrians and bicyclists accounted for 13% of deaths but they represent just 3% of state transportation trips. This is a terrible record. If you want to increase biking and walking, special attention needs to be paid to improving safety for these two groups. They should be given top priority. According to the table on page 140, fatal and serious injury crashes for pedestrians are at nearly the same level they were in 2004. So zero progress is being made in this category. This isn’t surprising since MnDOT, counties and cities spend very little money on improving pedestrian safety and fail to make it a priority. According to “Table 3,” city and town deaths have seen no real decline since 2004, yet cities and towns are where the majority of pedestrians and bicyclists are. If there isn’t rigorous collection of crash data by cities and towns, and MnDOT doesn’t make reducing bike/ped crashes a priority, then nothing is going to change.
MnDOT and the state collect absolutely no bicycle and pedestrian count data so they can’t know how many pedestrian and bike crashes are occurring per user. They collect traffic count data (via AADT counts) because these are automated and they can use this data to know how dangerous a road or intersection is per driver. They need to do the same thing for pedestrians and cyclists even if it means getting volunteer and paid counters to do the work manually at least once per year.
For example, a highly car-oriented MnDOT metro engineer named Wayne Norris is fond of saying that “most pedestrian crashes happen at signalized intersections,” as an excuse for not creating more signalized intersections. But the vast majority of pedestrians cross MnDOT trunk highways or state-aid boulevards at signalized intersections. So one death or injury at a signalized intersection like Snelling Avenue (TH 51) and Grand Avenue means less because over 200 people are crossing it every hour …versus one death or injury at an unsignalized intersection like Snelling Avenue and Ashland, where just 5-10 people cross per hour. So count data is critical to analyzing accident data and evaluating how dangerous a given intersection or stretch of road really is. The city of Minneapolis makes an effort to do bike/ped counts, using its Federal Pilot Program money and many other cities and states also do it. There is no reason why Minnesota can’t do it statewide.
Because of the lack of adequate statewide pedestrian and bicycle crash data and because of the total absence of statewide pedestrian and bicycle count data, many of the strategies listed in the plan may actually make conditions worse for cyclists and pedestrians.
For example, under “Intersection Key Strategies”, are roundabouts or traffic circles better for pedestrians? They might be better for cars but pedestrian and bicycle safety on them is less clear-cut, particularly with larger roundabouts. Large roundabouts lengthen the distance that a pedestrian has to walk to get through an intersection, lengthening pedestrian trip times and thus reducing pedestrian “Level of Service.” Also vehicle behavior coming off the roundabout is less predictable for pedestrians than it is at a traditional signalized intersection. It is therefore much more difficult for a pedestrian to know if a given car in the roundabout will be continuing around it or turning onto the street the pedestrian is attempting to cross.
The 85th% Folly
Under strategies, the plan fails to look at the agency’s own policies and how they impact pedestrians and cyclists. MnDOT requires “85th Percentile Speed Studies” to get a reduction in posted speed limits and has failed to make reducing speeds on its trunk highways in urban areas a priority. This is despite the fact that a vehicle’s speed is the primary determinant of whether a pedestrian or bicyclist hit by a motor vehicle will survive the crash.
Parts of Snelling Avenue (TH 51) rank #2 and #3 in the state for “Crash cost per mile” for bike and pedestrian crashes. Yet the agency refuses to consider lowering speed limits in key areas of that Avenue without an 85th Percentile Study, a policy which ensures that no speed reductions will ever take place. Another example is state requirements for placing signals at intersections.
Getting a traffic signal or a HAWK (High intensity Activated WalK) signal on a state-aid highway requires a certain number of pedestrians per hour. But these 4-lane boulevards (like White Bear Avenue, Snelling Avenue or parts of 7th Street in Saint Paul) are the hardest streets for pedestrians to cross. When community groups ask for a traffic light or HAWK signal, they are told, “You don’t have the requisite 20 (HAWK) or 90 (Full Signal) pedestrians per hour to qualify for one.” But this becomes a Catch-22. To get the requisite number of pedestrians, the city needs a signal for them to safely get across …but they can’t get the signal until enough people cross (and get hit or killed).
Safety is a Right
The plan fails to consider pedestrian and bicycle access to a given street or intersection as a human right and thus fails to consider the impact of large state-aid boulevards on communities. These streets often have over half-mile gaps between signalized intersections. This has the effect of dividing neighborhoods since crossing the street between signals is often impossible due to motor vehicle traffic volumes and speeds. At numerous meetings MnDOT and the Saint Paul Public Works Department have stated that they “don’t want to put a crosswalk or better pedestrian warning signage at one of these unsignalized intersections because they will give pedestrians the false impression that it’s safe to cross them.” Then they use MUTCD standards and the Minnesota State Highway Manual as an excuse to avoid having to do anything.
I am told that “technically” MnDOT can provide variances for signal requirements if a state-aid road is crossed by a city sanctioned bikeway or if there are other extenuating circumstances, but local engineers (who are often overworked) shy away from applying for variances because there is no standardized process or variance committee for signals or speed reductions the way there is for obtaining lane-width variances.
LPI vs. LOS
The plan could consider use of “Lead Pedestrian Intervals” or “LPIs” at signalized intersections to reduce right hook crashes like the one that recently killed a woman on Hamline Avenue in Saint Paul …or other specific strategies. But it doesn’t do this and agency policy has been to maximize “Level of Service” for cars, a policy which runs contrary to LPIs or strategies like shortening signal timings, and runs contrary to pedestrian and bicycle safety itself.
The plan’s “Appendix B” includes “Strategies from other plans and stakeholders” and there are many good suggestions including some of those I’ve presented in these comments. However, I see no effort to actually incorporate these strategy suggestions into the plan itself. (An example would be comment reference #194 on page 131.) It’s almost as if MnDOT has included this list to fulfill planning process requirements like the Administrative Procedures Act, so it can say (if ever questioned in court or elsewhere) “we read and heard comments.” But no effort is made to actually listen to the comments and separate the sensible from the ludicrous or impossible.
Furthermore, many current agency practices are diametrically opposed to the strategies in these lists. For example, #371 on page 127 suggests “Reduce turning radius at corners to slow traffic” but MnDOT and its partners are doing the exact opposite at several intersections on the I-35E Cayuga Project which are being designed with high-speed radii in areas that will be used by cyclists and pedestrians. The strategies in Appendix B are introduced “as an initial reference point for anyone wishing to champion safety improvements.” But this plan and MnDOT itself are supposed to “Champion safety improvements.” Instead, they are leaving it to others and putting out a plan that, as it relates to bicycles and pedestrians, is mostly fluff.
Show Me the Money
Finally the plan fails to evaluate how much money MnDOT and its partners are spending on bicycle and pedestrian data collection, engineering, education, infrastructure and enforcement, both in real dollars and as a percentage of total agency spending. Without this information, it’s impossible to look at what’s being spent and how much of an impact it might or might not be having.
The plan needs to mandate this spending data collection and make the data public. Then the plan needs to dedicate additional MnDOT money towards better data collection, engineering and enforcement measures that will reduce pedestrian crashes and increase pedestrian and bicycle access to public roadways. When we ask the agency to create a sidewalk or safe crossing of Interstate 94 at Century Boulevard, we are told they don’t have the money. We are told the same thing at McKnight Road and Interstate-94. Both highway underpasses are the only crossings of I-94 for many miles and both lack any safe bicycle access. Only McKnight has a (woefully inadequate) sidewalk on one side of a major 4-lane boulevard with poor to non-existent crossings of off-ramps, and busy intersections. These are underpasses used by school children, transit riders exiting buses and pedestrian and bicycle commuters going to and from 3M corporation.
The agency has heard about these problems from local activist groups for over fourteen years but they’ve done nothing to improve the situation. Yet MnDOT has money to build a new Stillwater Bridge to nowhere, add two new highway lanes to the Lafayette Bridge, widen Interstate 35E, Interstate 35W, The Crosstown and dozens of other Twin Cities highways at a cost of billions of dollars. So creating a “safety plan” that doesn’t focus attention on non-motorized users and doesn’t commit any money to improving their safety is a useless and bogus plan.
To summarize, this plan is a failure and should be completely redrafted to focus more attention on non-motorized street and road users. Its top priorities should be:
1. Require all cities and towns in the state to collect data on bicycle and pedestrian crashes and publish the data on a publicly available website. Agree on state standard crash data points that should be collected and published. These should include: Direction of travel of the victim; Direction of travel of perpetrator/motor vehicle; Exact location on a street or road where crash occurred; Time of day it occurred; Proximate cause; Etc.. If a city or town lacks funding to collect and publish data, MnDOT should provide it.
2. Collect pedestrian and bicycle count data on as many of these locations as possible so we can know how many crashes are occurring per pedestrian crossing or per cyclist user of the street. Only then can we know how dangerous a given intersection or piece of road really is and how best to spend scarce engineering money. Make this data public as well. When you make data public, it allows public institutions, NGOs and individuals do some of the analysis for you and allows outsiders to see and point out things that people inside an agency are unable or unwilling to look at.
3. Make reducing pedestrian and bicycle crashes with motor vehicles a top priority while increasing safe bicycle and pedestrian access to public streets and roadways. Clearly list the specific strategies you will be using by actually listening and evaluating the strategy suggestions you’ve received.
4. Look at and change internal agency policies regarding speed, signal placement restrictions, employee behavior and other issues than reduce pedestrian and bicycle safety and access.
5. Figure out and make public what percentage of MnDOT and partner agencies’ budgets are currently being spent on bicycle and pedestrian evaluation, engineering, education, enforcement and infrastructure, versus what these same agencies are spending strictly on motor vehicles. Analyze where safety spending has the potential to have the greatest impacts on bike/ped crashes and create a list of priorities, down to specific cities, towns and trunk highways.
6. State openly what the agency and its partners plan to spend on improving pedestrian and bicycle safety in the future and how and where it will be spent.
If you did those things, you’d have a real plan. What you have now is an overwhelmingly car-centric plan that doesn’t align itself with stated trends (on page 15) of increasing urbanization, aging population and increasing obesity and health problems. Responding to these trends requires that the state create a safe biking and walking environment. MnDOT should do the same things for bicycle and pedestrian safety as it is currently doing for motor vehicle safety. This plan fails to do that.
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