August 18th, 2016
Re: Docket 2013-0054: National Performance Management Measures; Assessing Performance of the National Highway System, Freight Movement on the Interstate System, and Congestion Mitigation and Air Quality Improvement Program
On behalf of MassCommute, a coalition of thirteen Transportation Management Associations (TMAs) in Massachusetts, I am writing to respectfully express our opposition to the proposed rule as it is currently constructed. The TMAs of MassCommute collectively represent over 300 businesses and employers with more than 300,000 employees in 45 municipalities across the Commonwealth and it is our mission to reduce traffic congestion, improve air quality and increase opportunities for economic development through innovative transportation solutions.
Specifically, MassCommute opposes the sole use of “Travel Time Reliability” & “Hours of Excessive Delay” as the only metric to describe system performance and congestion. We believe that per-person throughput (PPT) and/or average vehicle occupancy (AVO) should be incorporated as metric.
As organizations working directly with commuters in both urban and suburban locations, we recognize the impacts that commuting inflicts on people’s lives- personally, physically and professionally. We understand that ultimately transportation is important for what it does, not for what it is, and that when we focus too much on the roads and vehicles themselves rather than on the people who rely on them, we end up with a transportation system that serves only the needs of cars, not people. Cars are never late to pick up kids from daycare. Vehicles aren’t late to meetings. Performance measures should focus on the people that use the transportation system rather than the vehicles they use. Unfortunately, the metrics identified by this rule are vehicle focused and our transportation should be focused on moving people.
The measures put forth by this proposed rule will determine not only how state DOTs shape their transportation planning and decision making but how States prioritize their spending of billions of dollars in transportation investments. They are simply too important to get wrong. In this era of rapidly evolving technologies and innovative business models, these metrics should serve to advance rather than hinder these innovations and leverage them in ways that unleash rather than halt their potential. As currently proposed, the metrics focus only on the outdated model of getting X amount of vehicles through a point in Y amount of time which blatantly ignores this opportunity to reshape and reinvest in our transportation system.
MassCommute believes that PPT should be integrated into this rule and that the proposed rule include a way to phase in PPT. Specifically, this rule should allow the use of existing surveys (such as the American Community Survey) and other best practices over the next several years to gain a baseline of regional AVO. During that period, USDOT should work to identify, create, and incorporate more technology based methods of measuring AVO and PPT along corridors.
Finally, MassCommute has additional concerns about the rule as constructed, specifically:
Missing Data (page 266) –MassCommute strongly disagrees with the proposal to allow States to utilize the posted speed limit for missing segments. This will drastically skew data gathering if even just one 5-min bin does not have data. MassCommute recommends FHWA require States to use the average of the segment before and after a missing segment for an open data segment or two consecutive open data segments. Provided the strong statement of the ‘readily available’ nature of this data set, there should never be a case in which more than two data segments are empty. However, if there were to be an instance where three data consecutive data segments were empty, that section should be considered null and reported as such.
Speeds below 2 MPH – On page 270, FHWA says that speeds below 2 MPH should be excluded from the calculation. MassCommute objects to this. We recognize the intent to eliminate statistical anomaly’s, but States and MPOs should not be able to blindly exclude such data sets. Prior to excluding such data sets, States and MPOs should consult other data and information to verify that the data set was in fact an anomaly and not the actual state of congestion.
LOTTR Target Threshold – MassCommute believes that the threshold for a reliable segment is too low and should be raised to 1.25 (compared to existing level of 1.5) of expected travel time. Under the current proposal, a 1 mile segment with a speed limit of 60 MPH would be considered reliable if it took 50 seconds to transverse. Extrapolate that over a 60 mile segment and you would be ten minutes behind expected pace. Most of the commuting public would consider being ten minutes late as a state of ‘unreliable’.
The CMAQ is flawed in many ways specifically:
- · The metric is vehicle focused
- · Does not account for trips not taken and trips on transit/alternative modes –
- · Similar Concerns with Measuring Congestion Metric as concerns with subpart E –
- · 15/35 MPH baselines –
MassCommute is also very supportive of including CO2 as a measure. Please do not hesitate to contact either of us to discuss this further.
Julia Prange Wallerce, Executive Director Jeff Bennett, Managing Director
August 3rd, 2016
MassCommute received international recognition for innovation in Transportation Demand Management (TDM) work at the Association for Commuter Transportation international conference in Portland, Oregon.
MassCommute was proud to take the stage twice during the awards ceremony- first for our TMA White Paper, "Making the Shift: How TMAs in Massachusetts Leverage Private-Sector Resources to Achieve State Goals & Public Benefits" which won the Excellence in Research Award- and second for our ECO Awards (Excellence in Commuter Options) program with MassRides which won the Marketing and Outreach Award for a Public/Private Partnership.
The Association for Commuter Transportation, (ACT), announced the award winners during the 2016 international conference held in Portland, OR, July 31st - August 3rd. ACT represents major employers, public transportation departments, and private sector transportation providers to improve transportation options, livability and economic competitiveness.
More than 450 transportation professionals from federal, state and local governments, universities, and major businesses attended the conference that kicked off with an opening reception featuring U.S. Rep. Earl Blumenauer (OR-03), a leading voice in Congress for transportation options and livable communities. This year, 80 organizations were nominated for 18 awards in categories that include marketing, research and commuting options.
ACT president Robert Henry hailed winners as model programs in the TDM field. The full list of 2016 winners is available online: http://actweb.org/act-national-awards-winners-named-at-portland-conference/.
“Every day, every commute and every carpool is a journey,” Henry said. “As mobility rapidly changes with advances in technology, it is wonderful to see so many leaders working to improve our journeys and our environment at the same time.”
MassCommute is grateful to the 2016 ACT National Awards Committee & Judges for this great honor!
The Association for Commuter Transportation, (ACT), is an international trade association and leading advocate for commuter transportation and TDM. Commuting by bus, train, rideshare, bike, walking, or telework improves our world by contributing to energy independence, better air quality, sustainability, urban mobility, and reduced congestion. Through advocacy, education, and networking efforts, ACT strives to improve the lives of commuters, the livability of communities, and the economic competitiveness of businesses.
June 10th, 2016
2016 MassCommute Bicycle Challenge breaks the record with 156,285 miles biked, 145,862.26 pounds of CO2 emissions saved
City of Cambridge winning community in 2016, MIT Lincoln Labs wins business category
The 22nd annual MassCommute Bicycle Challenge (MCBC) successfully inspired over 2,400 Massachusetts residents, employees, and students to log a record breaking 156,285 miles by bike during Bay State Bike Week this past May 14th-22nd, exceeding the 2015 record by 10,200 miles!
Each year, during Bay State Bike Week, the twelve TMAs of MassCommute challenge Massachusetts travelers to take as many trips as possible by bicycle and log them on the MCBC website. The Challenge is a free and friendly competition between businesses, communities, and institutions for fun and fitness, and seeks to encourage bicycling as a viable mode of transportation.
MassCommute is particularly proud of this year’s results:
In addition, over 200 people came out to celebrate the winners and raffle off some great prizes at the Bike Bash held at Flat Top Johnny’s on June 1st (check out the photos at http://tinyurl.com/bikebashpics)
Over the last two decades, the MCBC has become a signature event of Bay State Bike Week. From daily bike breakfasts and raffles to tune-ups and safety workshops to commuter convoys and bike parties, the MCBC is both an opportunity celebrate the joys and benefits of biking and to engage in some friendly competition with our fellow commuters, communities and businesses/institutions. It is also an opportunity for employers to show support for cycling as a real, valuable transportation choice for their employees (84% of trips logged during the Challenge were for commuting/general transportation!) by forming teams and/or sponsoring the event.
Huge congratulations to our 2016 winning teams, communities & individuals!
MassCommute extends a heartfelt THANK YOU to our generous MCBC 2016 sponsors:
MassCommute provided the following comments in response to MassDOT's 2017-2021 Capital Investment Plan (CIP):
May 13th, 2016
Re: Comments on the Draft FY2017-2021 CIP
Dear Secretary Pollack,
On behalf of the twelve transportation management associations (TMAs) of MassCommute, I am pleased to submit this letter in response to the draft five-year capital investment plan (CIP), and thank you for the opportunity to do so. Many of our TMAs and their members have participated in the public meetings and we all look forward to reviewing the final approved CIP later this month.
Our coalition is deeply grateful for our partnership with MassDOT, and for the state’s commitment to supporting TMAs through the federal CMAQ program. These funds provide a critical platform from which TMAs are able to engage businesses and employers and leverage private sector investment in solving transportation challenges through innovative transportation demand management (TDM) solutions. We applaud the Baker Administration for combining the MassDOT and MBTA investment plans into one coherent investment blueprint and look forward to continuing our work together in support of MassDOT’s priorities to maintain, modernize, and- where prudent, expand our transportation system.
Acknowledging the shortfall of resources with which the state has been left to fix our current transportation system and build the system we need, we are pleased to see that the following investments have been included in the CIP:
- Green Line Extension: Consistent with the board’s May 9th vote, we hope that this project remains a commitment in the final CIP, as well as the Community Path.
- Bicycle and pedestrian infrastructure on roads, sidewalks, and multi-use paths.
- Complete Streets Program: Fully funding this innovative program will allow our communities to make our roads safer and more accessible to everyone.
- State of good repair: Eventual spending of $765 million per year for much needed MBTA repairs is a significant increase over previous years’ spending and will provide real effects on the level of service provided to riders. We hope you will continue to increase this annual investment amount to account for inflation and anticipated increases in construction costs.
- Fairmount Line and Blue Hill Ave Commuter Rail station: Strategic investments along this corridor will yield significant benefits to commuters and provide improved jobs connections to underserved communities
Overall, we feel that this is a strong plan that invests $14.4 billion dollars over the next five years and demonstrates that Massachusetts is strongly committed to expanding and improving public transportation and bicycle and pedestrian infrastructure. We hope that this CIP continues to provide even more resources for transportation investments across the state that will allow our transportation system to keep up with our growing and changing economy. Today’s workers are hungry for transportation options and alternatives to the drive alone commute; our TMAs look forward to continuing to build and strengthen public private partnerships to ensure that those options are available.
Thank you for the opportunity to respond to this plan, and for your dedication to making Massachusetts an even better place to live, work, and do business. Please do not hesitate to contact either of us with any questions.
Julia Prange Wallerce, Executive Director Patrick Sullivan, Managing Director