June 11, 2021 Wade Holland Vision Zero Coordinator Office of the Montgomery County Executive 101 Monroe St, 10th Floor Rockville, MD 20850 visionzero@montgomerycountymd.gov Re: Draft Vision Zero 2030 Plan Dear Mr. Holland: Please accept these comments on the draft Vision Zero 2030 Plan on behalf of the Coalition for Smarter Growth, the leading organization advocating for walkable, bikeable, inclusive, transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. We commend Montgomery County for its commitment to ending all traffic fatalities and serious injuries. Vision Zero is important for many reasons, chief among them to make our transportation system one where all users can safely move. We cannot create great places for people to live, work, and play in Montgomery County if people do not feel safe getting there. The county also faces other challenges, such as the county’s rapidly aging population who would like to age-in-place and combating climate change, of which Vision Zero is a critical component of the solution. In Vision Zero’s implementation, a focus on equity is critical. Thus, we are pleased by the prioritization of disproportionately impacted communities for infrastructure investments, outreach, and efforts to reimagine public safety. We are also glad to see the county shift away from the traditional “3 E’s” approach to recognize that enforcement and education are important, but complementary to the primary work of safe street design. Below are our detailed comments on the draft plan: ●
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Collaboration with the State Highway Administration: There is not enough detail in the plan about how Montgomery County will work with the Maryland State Highway Administration to implement Vision Zero improvements. This is of critical importance given that 53% of serious and fatal collisions occur on state maintained roadways. Collaboration with the County Council: The organizational oversight and partnerships section (page 23) is very focused on the executive branch and not the County Council, even though the County Council makes final decisions on funding for Vision Zero improvements and is in frequent contact with constituents concerned about deaths and injuries on the county’s roads. There need to be further steps taken to ensure that councilmembers are engaged on Vision Zero.
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Priority actions: Actions S-2: Intersection Redesign and S-11: Improved Lighting are not listed as priority actions, but they should be, given the data. Over 50 percent of serious injuries and fatalities for motorists, pedestrians, and cyclists are intersection related, including 66 percent of serious cyclist injuries. Similarly, nighttime crashes make up a disproportionate amount of serious injuries and fatalities, including 66 percent of pedestrian deaths. Issues as obvious and prevalent as intersection design and street lighting need to be prioritized for action. Improved lighting: Furthermore, Action S-11 needs a more detailed work plan. It is unclear whether updating the county’s streetlight policy will actually result in more lightbulbs being replaced. This is a challenge throughout many of the proposed actions. We would like to see more work plan items like “refresh/install at minimum 500 crosswalks with continental striping” under Action S-14: High Visibility Equipment and Markings. Whenever possible, work plan items should be quantifiable and measurable. Work plans: Additionally, it is difficult to tell whether the proposed FY22 and FY23 work plans achieve geographic equity and are properly focused on the High Injury Network. A comprehensive analysis of the biennial work plan would be helpful to make sure it is successful. Enforcement: As per the County Executive’s Reimagining Public Safety Task Force recommendations, the county should move to a fully or nearly fully automated traffic enforcement system. We also support the movement to remove police from traffic enforcement. Allowing police with weapons to enforce traffic laws puts people in danger of undue use of force, especially Black and brown persons. Automated enforcement must also be implemented with equity in mind, using data to determine automated enforcement locations. Fines and other consequences for not complying with traffic laws should also be determined with equity in mind. Ideally our streets should be designed in such a way that traffic enforcement is not as necessary. School bus stop safety: The work plans of Action T-3: School Bus Stop Safety should not be to move school bus stops to less convenient local streets, but to reengineer the major roadways to be places that are safe for students to wait for the bus. Parking lots: In reference to Action T-9, Parking Lot Design and Construction, if 16% of serious and fatal pedestrian-involved crashes occur in parking lots and driveways, then it is not enough to just look at parking lots when they are redeveloped or built. The county should also work with property owners to redesign existing, high-crash parking lots with safety in mind. Imparied driving: We understand the interest in developing a separate action plan focused on ending impaired driving deaths (FY22 work plan for Action P-4: Ending Impaired Driving Deaths), but urge you to include items that can be incorporated into the 2030 plan now, such as expanding the hours and improving accessibility of public transportation. Not included: The recent update to Montgomery County’s Growth and Infrastructure Policy made changes to address Vision Zero. Has the county identified additional changes for the 2024 update that could further address Vision Zero?
Sincerely, Jane Lyons
Maryland Advocacy Manager Coalition for Smarter Growth CC:
County Executive March Elrich Montgomery County Council Montgomery County Planning Board Gwen Wright, Montgomery County Planning Department Director Christopher Conklin, Montgomery County Department of Transportation Director