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Complete Streets Resolution, Policy Guidance and Template

Post Date: 1/30/2012

DRAFT Regional Complete Streets Resolution

01/30/2012

WHEREAS, the term "Complete Street" means a travel corridor that safely and adequately accommodates motorized and non-motorized users, including pedestrians, bicyclists, motorists, freight vehicles, and transit riders of all ages and abilities, and.

WHEREAS, the terms ‘‘complete streets policy’’ and ‘‘complete streets principle’’ mean

A transportation law, policy, or principle at the local, state, regional, or federal level that ensures the safe and adequate accommodation, in all phases of project planning, development, and operations, of all users of the transportation network, including pedestrians and transit riders of all ages and abilities, bicyclists individuals with disabilities, motorists, and freight vehicles; and

WHEREAS, streets that are not designed to provide safe transport for all users present a

danger to pedestrians, bicyclists, and riders of public transportation, most especially children,

older adults, and people with disabilities; and

WHEREAS, Complete Streets are essential in providing safe routes to school for

children; and

WHEREAS there has been a drop in motorized fatalities since 2006, but there has not been a corresponding drop in non-motorized fatalities, and

WHEREAS, pedestrians and bicyclists now account for 30% of the region’s transportation fatalities, and

WHEREAS, Complete Streets will support the regional goal of reducing injuries and deaths on our streets, and

WHEREAS, streets are a key public space, shape the experience of residents and visitors

to the Washington Region, directly affect public health and welfare, and provide the framework

for current and future development; and

WHEREAS, the Transportation Planning Board wishes to encourage walking, bicycling, and the use of public transportation as safe, convenient, environmentally friendly, and economical modes of transportation that promote health and independence for all people; and

WHEREAS, sedentary lifestyles and limited opportunities to integrate exercise into daily

activities are factors contributing to increased obesity among adults and children and numerous

correlated adverse health consequences; and

WHEREAS, Complete Streets will support federal and regional public health

efforts by providing opportunities to integrate exercise into daily activities, and

WHEREAS, Complete Streets will support efforts to reduce ground level

pollution, greenhouse gas emissions, and decreases noise pollution, and

WHEREAS, a network of Complete Streets is safer and more appealing to

residents and visitors, which will enhance retail and commercial development, and

WHEREAS, the one-third of Americans who do not drive include a disproportionate

number of older adults, low-income people, minorities, people with disabilities, and

children, and the inequitable distribution of safe alternative means of travel adversely affects

their daily lives; and

WHEREAS, the dramatic increase in the population of older and very old adults that will

be seen by 2020 and 2030, requires that changes be made now to street design and transportation

planning; and

WHEREAS, a network of Complete Streets will allow more people – particularly people with disabilities, older adults, children under 16, and those without cars – to get out and stay connected to the community, and

WHEREAS, the Transportation Planning Board recognizes that the careful planning and coordinated development of Complete Streets infrastructure offers long-term cost savings for local and state government, benefits public health, and provides financial benefits to property owners, businesses, and investors, while creating a safe, convenient, integrated transportation network appropriate for the land use or the context of the street; and

WHEREAS, the TPB’s Bicycle and Pedestrian Plan for the National Capital Region (2010), COG’s Region Forward (2010) and the TPB Vision (1998) promote goals linked to Complete Streets, such as

· Convenient bicycle and pedestrian access

· Making the region's transportation facilities safer, more accessible and less

intimidating for pedestrians, bicyclists, and persons with special needs

· Improved internal mobility with reduced reliance on the automobile within the

regional core and within regional activity centers

· Increased transit, ridesharing, bicycling and walking mode shares

· improved pedestrian and bicycle safety, walkable mixed-use communities, community connectivity, and reduced reliance on driving, and

WHEREAS, the Transportation Planning Board desires that its streets form a comprehensive and integrated transportation network promoting safe, equitable, and convenient travel for users while preserving flexibility, recognizing community context, and using the latest and best guidelines and standards, and

WHEREAS, many but not all of the TPB’s member jurisdictions have approved Complete Streets policies, or are in the process of revising existing policies, and,

WHEREAS, the TPB wishes to encourage its member jurisdictions to adopt their own Complete Streets policies that incorporate common elements which the TPB believes represent current best practices, and

WHEREAS, on June 15^th, 2011 the Citizens Advisory Committee requested that the TPB develop and approve a regional policy on Complete Streets, and

WHEREAS, on June 15^th, 2011 the Citizens Advisory Committee recommended, and the TPB Chair requested, that the Bicycle and Pedestrian Subcommittee advise the development of a regional policy on Complete Streets with input from the Access for All Subcommittee, the Bus Subcommittee, the Citizens Advisory Committee, and members of the general public, and

WHEREAS, the Bicycle and Pedestrian Subcommittee of the TPB Technical

Committee, which includes bicycle and pedestrian planners from the TPB state and

local jurisdictions and representatives of bicycle user and pedestrian organizations, has

advised the development of the draft Complete Streets Guidance and Policy Template for the National Capital Region, and

WHEREAS, on _______, 2012, the TPB Technical Committee recommended

favorable action on the Complete Streets Guidance and Policy Template for the National Capital Region,

NOW, THEREFORE, BE IT RESOLVED THAT THE NATIONAL CAPITAL REGION TRANSPORTATION PLANNING BOARD approves the Complete Streets Guidance and Policy Template for the National Capital Region.

DRAFT

Complete Streets Guidance and Policy Template for the National Capital Region

01/30/2012

I. Purpose

The purpose of this Complete Streets guidance and policy template is to encourage TPB member jurisdictions and agencies that do not already have a Complete Streets policy, or who are revising an existing policy, to adopt a Complete Streets policy that includes common elements that the TPB believes represent current best practices.

II. Definitions

(1) COMPLETE STREET.—The term ‘‘complete street’’ means a travel corridor that safely and adequately accommodates motorized and non-motorized users, including pedestrians, bicyclists, motorists, freight vehicles, and transit riders of all ages and abilities.

(2) COMPLETE STREETS POLICY; COMPLETE STREETS PRINCIPLE.—The terms ‘‘complete streets policy’’ and ‘‘complete streets principle’’ mean

III. Ten Elements of an Ideal Complete Streets Policy

The following ten elements, which are endorsed by the National Complete Streets Coalition, should be part of a comprehensive Complete Streets policy. An ideal Complete Streets policy:

Includes a vision for how and why the community wants to complete its streets.

Specifies that “all users” includes pedestrians, bicyclists and transit passengers of all ages and abilities as well as trucks, buses and automobiles.

Encourages street connectivity and aims to create a comprehensive, integrated, connected network for all modes.

Is adoptable by all agencies to cover all roads.

Applies to both new and retrofit projects, including design, planning, maintenance, and operations for the entire right of way.

Makes any exceptions specific and sets a clear procedure that requires high-level approval of exceptions.

Directs the use of the latest and best design standards while recognizing the need for flexibility in balancing user needs.

Directs that complete streets solutions will complement the context of the community.

Establishes performance standards with measurable outcomes.

· Includes specific next steps for implementation of policy.

IV. Complete Streets Policy Template

Beginning on the effective date of this policy, all publicly funded or maintained transportation projects in (insert Jurisdiction or Agency) shall accommodate the safety and convenience of all users in accordance with Complete Streets principles.

Inclusions

1. All publicly funded or maintained transportation projects funded shall accommodate the safety and convenience of all users in accordance with Complete Streets principles. Roadways, sidewalks, shared use paths, street crossings, pedestrian signals, signs, street furniture, transit stops and facilities, and all connecting pathways should be designed, constructed, operated and maintained so that all users, including pedestrians, bicyclists, transit vehicles and riders, freight vehicles, motorists, and people with disabilities, can travel safely and independently.

2. Complete Streets principles shall apply to new road construction and road modification projects, including design, planning, construction, reconstruction, rehabilitation, maintenance, and operations, for the entire right of way. In particular,

o The design and construction of new facilities should anticipate likely future demand for bicycling and walking facilities and not preclude the provision of future improvements.

o Transportation projects should address the need for bicyclists and pedestrians to cross corridors as well as travel along them. Even where bicyclists and pedestrians may not lawfully travel on a roadway that is being improved or constructed, they will likely need to be able to travel along that corridor and to cross that corridor safely and conveniently. Therefore, adequate and nearby parallel travelways should be provided or improved and the design of intersections and interchanges should accommodate bicyclists and pedestrians in a manner that is safe, accessible and convenient.

o Safe and adequate rail crossings for motorized and non-motorized users should be provided. Where safety and security considerations permit, rail transit and freight rail projects should accommodate non-motorized users within the travel corridor, especially on new and reconstructed rail transit and freight rail bridges.

o Transportation projects should address the need for pedestrians and bicyclists to access transit. Transit users rely on walking and cycling to link transit stops with destinations and special attention must be given to facilities near transit for traveling along roads, crossing roadways, and connectivity to destinations.

3. Improvements for the safe and convenient travel by pedestrians or bicyclists on, along, and across streets should be fully assessed, considered, and documented as a routine element of pavement resurfacing projects.

4. Transportation projects should comply with up-to-date design standards, particularly standards relating to providing access for individuals with disabilities. Construction, maintenance and operations should be conducted in such a manner as to maintain safe and adequate access for pedestrians, including individuals with disabilities.

5. Complete Streets principles should be applied in due consideration of the urban, suburban, or rural context in which a project is located. While all users should be accommodated, modal priorities may vary by area and facility. One size does not fit all.

Exemptions

1. This policy shall not apply to a new road construction or modification project for which, as of the effective date of the adoption of the policy, at least 30 percent of the design phase is completed.

2. An affected roadway prohibits, by law, use of the roadway by specified users, in which case a greater effort should be made to accommodate those specified users elsewhere in the travel corridor, including on (or along) parallel roadways and roadways that cross or otherwise intersect with the affected roadway.

3. The cost to the exempted project in achieving compliance with the applicable complete streets policy would be excessively disproportionate (as defined in the 2001 US Department of Transportation Guidance on Accommodating Bicycle and Pedestrian Travel), as compared to the need or probable use of a particular complete street; or

4. The existing and planned population and employment densities or level of transit service around a particular roadway are so low that there is a documented absence of a need to implement the applicable complete streets policy,

5. While safe and adequate rail crossings should be provided, passenger and freight rail projects shall not be required to accommodate other motorized users in the railway right of way.

6. Project-specific exemptions shall be approved by a senior manager of the responsible agency.

V. Documentation and Reporting

1. Transportation Planning Board staff shall conduct a periodic survey of the TPB member agencies regarding their adoption and implementation of Complete Streets policies.

2. Transportation Planning Board member agencies will be asked to report periodically on the pedestrian and bicycle facilities that have been newly created or substantially improved.

3. Implementation of Complete Streets principles may be measured in the regional Transportation Improvement Program.

VI. Promotion

As feasible, the Washington Region will conduct training on Complete Streets best practices for personnel responsible for the design, construction, and maintenance of streets.

Author: Michael Farrell

Comments:

	Ochia, Krys - 2/10/2012
Purpose statement: I suggest that the word “institutionalize” replaces the word “includes” “common elements that the . . . “ Under exemptions, Item #1. So if it is 40% complete it is ok, since the minimum is 30%? Maybe, consider a finite number such as “where the design is at no more than 20% complete.” Item #4, The sentence may start with “There is documented absence of a need . . . “ so that in the end the word “low” is eliminated from the entire sentence; Otherwise, you may need to define the word “low.”

	Allen Muchnick - 2/10/2012
All, To my knowledge, the regional bike/ped database has never been updated in a comprehensible manner, so citizens, planners, and policy makers can reliably track how the region and various localities are adding and improving various types of bike and ped facilities. This failure, over the past half-decade, with updating the regional bike/ped database clearly illustrates why the region's addition and improvement of bike and ped facilities needs to be tracked and reported annually. Sure, a bi-annual, tri-annual, or quad-annual update cycle could be adopted as a "compromise', but staff work would not be significantly less, and the data would likely be less reliable as well as less timely. How time-consuming and "off-mission" would it be for each implementing agency to report on the bicycle and pedestrian projects and facilities it has completed construction of in any given year? Moreover, rather than hampering the "more important" work of the implementing agencies, an annual tally of completed and improved bicycle and pedestrian facilities would better focus the agencies on achieving real progress. "If it's not measured, it's unimportant" Allen Muchnick, board member Virginia Bicycling Federation allenmuchnick@yahoo.com 703-271-0895

	Cindy Engelhart - 2/10/2012
Michael and attendees: Here are VDOT’s Comments on the latest 1/30/12 revision of the Complete Streets Guidance Document and resolution statement sent out after the workshop. Most are minor editorial items which I don’t think will be an issue with the stakeholders, but a few need discussion. 1. Resolution statement: a. While we do not object to any individual point, we find there are repetitive items which can be consolidated or simplified. For example, the 8th, 9th, 10th and 11th bullets all address health issues. In addition bullets 14 and 16 list “people who do not drive” or “people who do not have a car”. b. In the third paragraph: One of the workshop stakeholders asked for the word, “convenience” to be added to the definition of the complete streets policy/principle. We have no objections to that change. We also have no objections to the request by a stakeholder who asked for the phrase “quality of life” to be included in the resolution. 2. Draft guidance: a. Section II, Definitions – i. Item 1) During the workshop one of the stakeholders expressed concerns over the term “travel corridor” in the definition of “Complete Streets”. It was noted that the current definition could imply a metro corridor might be required to accommodate freight as well as a bicycle/pedestrian facility. To avoid this un-intended interpretation, the attendees settled on the term “road” instead, with the suggestion to define it for the purposes of this document. Unfortunately further investigation found that the FHWA’s MUTCD legally defines the term “road” to equal “roadway” which excludes sidewalks and shoulders. In addition the definition of “street” is equated to “highway” which is “a public way for the purposes of vehicular travel including the entire area within the Right of Way”. Since these terms exclude either sidewalks or pedestrians, we feel they would not be appropriate terms for the definition. Therefore in an attempt to see how other agencies address this definition, 8 example policies were reviewed. They used various terms, but none of them defined the secondary term (road, roadway, etc.) probably to avoid the conflicts mentioned above. However one, Caltrans, had a good solution to this issue. They used: “Complete Street - A transportation facility that is planned, designed, operated, and maintained to provide safe mobility for all users, including bicyclists, pedestrians, transit riders, and motorists appropriate to the function and context of the facility.” Therefore to clarify our definition, we propose following the Caltrans example as follows: COG: The term ‘‘complete street’’ means a transportation facility that safely and adequately accommodates motorized and non-motorized users, including pedestrians, bicyclists, motorists, freight vehicles, and transit riders of all ages and abilities, appropriate to the function and context of the facility. So do the rest of the workshop attendees view this as an acceptable solution? Since Montgomery County, initially raised this concern, we would be interested if this phrasing addresses their concerns. a. Section IV, Complete Streets Policy Template, i. Introductory paragraph. Delete the word “maintained” since it is covered later in the detailed listing given under items 1 and 2. Beginning on the effective date of this policy, all publicly funded or maintained transportation projects in (insert Jurisdiction or Agency) shall accommodate the safety and convenience of all users in accordance with Complete Streets principles. ii. Inclusions, Item 1. Delete this sentence since it repeats the one immediately prior to it. All publicly funded or maintained transportation projects funded shall accommodate the safety and convenience of all users in accordance with Complete Streets principles. iii. Inclusions, Item 1. We recommend add the word “shoulders” in the second sentence, to read: Roadways, shoulders, sidewalks, shared use paths, street crossings, pedestrian signals, ……. iv. Inclusions, Item 2, bullet 2. We recommend changing the phrase, “Therefore, adequate and nearby parallel travelways should be provided or improved and the design…..” to read instead as, “Therefore, adequate and nearby parallel facilities should be provided if feasible or improved and the design…”. The term “travelways” is very similar to the AASHTO defined term “traveled way” and may cause confusion since the AASHTO term only applies to vehicular roadway lanes. v. Inclusions, Item 3. Pavement resurfacing projects. This is a modification so we recommend it be moved up to a bullet under item 2. vi. Exemptions. This needs a grammatical correction. Items 1, 5 and 6 are independent statements, but 2, 3 and 4 need an introductory phrase. Recommend saying, ”This policy does not apply to:” at the beginning of the section and adjust the others as needed. vii. Exemptions, Item 2. We adding the following modification shown in red: “…….elsewhere in the travel corridor, including in the Right of Way or Limited Access (but physically separated), on (or along) parallel roadways and roadways that cross or otherwise intersect with the affected roadway.” viii. Exemptions, Item 3. The statement saying cost is excessively disproportionate should not reference a specific document since they get superseded and revised. We recommend deleting (as defined in the 2001 US Department of Transportation Guidance on Accommodating Bicycle and pedestrian Travel) and saying “as per FHWA guidance”. ix. Exemptions. Item 6 is not an exemption b. Section V, Documentation and Reporting, item 2 – recommend the following addition in red. “Transportation Planning Board member agencies will be asked to report periodically in the Bicycle Pedestrian Database on the pedestrian and bicycle facilities that have been newly created or substantially improved. c. Section V, Documentation and Reporting, item 3 – recommend the following addition in red. Implementation of Complete Streets principles may be measured in the regional Transportation Improvement Program with the details proposed by COG staff and reviewed for recommendation by the TPB Technical Committee.

	William Handsfield - 2/10/2012
Michael, Two comments regarding draft regional complete streets policy: 1) Current draft of Complete Streets statement does not mention that streets must interact and facilitate the viability of the destinations along them. We would like one of the clauses to mention something to the effect of “streets are in and of themselves destinations, community gathering places, and areas for commerce” rather than just serving a transportation role. 2) We would also like the draft policy to mention stormwater management, tree boxes, and minimizing impervious surface. All of these are important for the region to meet its collective responsibilities to the Potomac & Chesapeake watersheds. Here is what DC has in our complete streets policy on that front: Improvements to the right of way shall consider environmental enhancements including, but not limited to: reducing right-of-way storm water run-off, improving water quality, prioritizing and allocating sustainable tree space and planting areas (both surface and subsurface), reusing materials and/or using recycled materials, and promoting energy conservation and efficiency wherever possible; William Handsfield Capital City Fellow DC Office of Planning 1100 4th Street SW, Suite E650 Washington, DC 20024 Desk: (202) 741-5219/Mobile: (310) 945-8545 william.handsfield3@dc.gov www.planning.dc.gov Visit the DC Office of Planning on Facebook and on Twitter @OPinDC

	Kevin Posey - 2/10/2012
Cindy, I concur: "transportation facility" seems to be the terminology to use. Road and/or roadway is not appropriate. I have reservations about item 2/a/iv. The word, "feasible", seems too broad an exception. I would prefer phrasing more along the lines of "if at all possible". This raises the threshold for exceptions (and doing nothing). Also, 2/b uses the word, "periodically," which is too vague. I would recommend "annually" in its place. Thanks Kevin H. Posey, Chair Alexandria Transportation Commission

	Adam Greenstein - 2/10/2012
“WHEREAS there has been a drop in motorized fatalities since 2006, but there has not been a corresponding drop in non-motorized fatalities…” – How is a drop in motorized fatalities defined? Is it based on an average over all years since 2006 or a year-by-year trend? Also, there can be a drop in fatalities when comparing 2 or more years, but the difference must be deemed statistically significant (otherwise it could be deemed coincidence or happenstance with extenuating circumstances not being accounted for in the comparison). “:WHEREAS, the dramatic increase in the population of older and very old adults that will be seen by 2020 and 2030, requires that changes be made now to street design and transportation planning…” – A more concrete definition of “older” and “very old” adults should be considered, possibly by providing age ranges, in this condition and any other conditions in this document involving age groups. Thanks, Adam Greenstein MDOT Office of Freight and Multimodalism

	Christine Green - 2/10/2012
To: Michael Farrell, Transportation Planner IV, Metropolitan Washington Council of Governments From: Christine Green, Washington D.C. Regional Policy Manager, Safe Route to School National Partnership Subject: Comments on the Complete Streets policy template Date: February 6, 2012 My comments on the policy template are based on my previous experience with the National Complete Streets Coalition. The current template is very strong in the basics of Complete Streets policies-clearly stating all users, specifying all phases, clearly defining exemptions AND assigning senior manager responsibility. There are two areas that are a focus at the National level and would be great to see improved here. Performance measures and Implementation (p. 20-21 in the Policy Analysis) Specify types of performance measures that may be utilized to spark ideas for jurisdictions using this as a template. The Policy Analysis document (linked above) ranks high scoring policies. Arlington County is the third highest rated policy for their performance measures. The performance measures are listed throughout their transportation plan. Another high scoring local policy is Baltimore. Performance measures are listed on page three of Baltimore's policy. It is important that we begin to measure all modes if we are going to consider all modes. The data is needed to inform decisions. A set of common multi-modal performance measures would benefit the region. Implementation is a crucial piece to a Complete Streets policy. It ensures that well written policies do not sit on shelves. The Policy Analysis provides options for implementation language including specifying action on at least two of the four steps to implementation and or assigning responsibility for implementation to a person or advisory board. In the Documentation and Reporting sections, I do encourage that there is a set timeframe for data collection-hopefully annually and definitely on a set schedule. Most agencies are collecting new pedestrian/bicycle facilities and collisions anyway and it would be an easy number to send to you. There was also some talk of freight at the meeting. The purpose of a policy is to make it mandatory that all modes are considered in the planning, design and operation. Freight is not only important for railroad crossings-which seemed to be focused on in the meeting- but for truck traffic as well. If a road being considered does not involve freight, than an engineer does not need to go any further, it is simply not part of the process. However, many truck routes, run through neighborhoods or on streets that are major connectors in communities and therefore pedestrians and cyclists will be on those streets and those interactions need to be considered. I would also like to comment on the “should” versus “shall” conversation. Complete Streets policies are flexible by design in their decision making process. But a strong policy requires that all users of all modes be considered. The flexibility comes in the decision making process of how to accommodate all users not that all users should be accommodated. On my copy, “shall” is still used under Inclusions in #1 and #2 and I hope that language remains. I would like to see “shall” for the major points such as #3-5 under Inclusions as well.

	Tina Slater - 2/10/2012
I like Alan's idea of annual updates to the regional bike/ped database. It would keep us focussed on the mission to include more modes of convenient travel for the public. This would provide outside groups (like WABA and GreaterGreaterWashington) the baseline data for documenting all newly added routes and they could help point out areas where there are gaps that, with a little bit of funding, might provide a whole lot of "connectivity" , giving a large "bang for the buck!" In an era of tight budgets, these might be prime targets to pursue. And he's right, too, about "If it's not measured, it's not important." --- Tina Slater, President Action Committee for Transit www.actfortransit.org

	Cindy Engelhart - 2/10/2012
While it would be great to have that data, I’m afraid I have to express the same concern that Mike Farrell mentioned regarding the amount of time we would have to spend on each update. It is not a small task. I have found out from my boss that the prior update was in 2006 when the overall bike plan was updated, so that would indicate it is on a 4 year cycle. Making the reporting annually would quadruple the amount of time required. Rather than focusing, I would say it could distract us from projects like COG’s regional routes, Street Smart, USBR 1 revisions, gathering our counts, working on projects, etc. Since these all take time to do….and we all have had manpower cuts. I will need to see if I can find out how long our last update took.

	Chris Wells - 2/10/2012
Just to toss more heat on the flame, beyond the workload of updating, we have about 250 pedestrian projects at about $60 million, and were told that was too much, might hurt some of the other jurisdictions feelings (kidding ;-), but that basically was too much, so just list it as a group, which didn’t seem to give the PR due, but admittedly a lot of projects to list status, project manager, ever changing timelines and budgets, so we’ve never been able to devote the staff time to update COG’s list, we have enough trouble keeping our internal lists relevant. Thanks, Chris Wells Pedestrian Program Manager Fairfax County

	Edgar Gonzalez - 2/10/2012
Michael: Thanks for extending the deadline for comments. We are in the middle of the CIP discussions with Council staff, leading to discussions with Council Committees. This is a very time consuming task. So here are some of my comments on the 01/30/2012 Draft, broken into general and specific GENERAL COMMENTS 1. I had prepared a redlined version of the latest document you had provided before the meeting and was prepared to discuss it at the meeting. However, a different document was presented at the meeting for discussion by all. Our work was then significantly affected by the change. 2. This is supposed to be a template document for consideration by the state and local agencies. The language provided should therefore be in the form of suggestions, not as mandates. My jurisdiction for example, has an Executive and Council that pass laws, including on the road code and design standards. The TPB cannot impose or mandate such things on the jurisdictions. So, keep the language more in the form of suggestions. 3. There is too much detail under Inclusions and Exemptions in Section IV. Stick to the policy statement (generally the first two or three lines maximum). Leave the details to the implementing agencies. State the goal, not necessarily how to achieve it. Things change, and the region has different ways to achieve the goal. 4. The suggested policy totally ignores environmental mandates and regulations that we must comply with. So, include some wording on the need to balance desirable outcomes from a pedestrian-bicyclist perspective, with those interests to protect the environment. As I mentioned at the meeting, sometimes the two policies conflict with each other, and the implementing agencies must balance those needs and conflicting interests in the implementation of a road project. SPECIFIC COMMENTS 1. Section III is totally new to the discussion. There is however, little new here, that is not already covered under Section IV Inclusions and Exceptions. There may be one or two ideas not already covered. Suggest this Section be totally removed and those items that may not be covered under section IV, be included there. There is too much repetition and that creates confusion as the language is very similar but not totally identical. Avoid confusion and consolidate in one Section only. 2. Complete Streets must also accommodate "emergency vehicles". Include them in the definitions, Section II. 3. Under Inclusions in Section IV, there are several references to "transportation projects". Change that to "road projects", as discussed at the meeting. See for example, #1; #2 bullets 2 and 4; and #4. 4. Suggest you add a #6 under Inclusions: "6. Complete Street Principles must be balanced with State and Local Environmental requirements covering the same road project." 5. Under Inclusion 1. Leave in the first two lines and delete the rest. There is too much specificity in the additional language, and when you really think about it, it creates conflicts with the C.S.P. 6. Under Inclusion 2 bullet 1. Insert on the second line, after walking facilities..."in accordance with Locally Approved Master Plans..." and delete the rest. 7. Under Inclusion 2, bullet 2: Change Transportation to Road. Delete everything after the first sentence. The suggested policy should not include all these details. You may discuss them in support of the statement, but they don't belong in the policy itself. 8. Under Inclusion 2, bullet 3: Stop after the first sentence. Again too much detail for a suggested "policy template". 9. Under Inclusion 2, bullet 4. Stop after the first sentence. Delete the rest. 10. Add a new Inclusion 6: 6. "Complete Street Principles must be balanced with State and Local Environmental requirements covering the same road project." Under Exemptions: Suggest you reformat the first line as follows: "The suggested Policy shall not apply for: 1. A new road ....etc.... 2. An affected road where it is prohibited by law the use of the road for specified users. (Then stop there. No need for more detail in a suggested "Template". 3. Stop the suggestion after the words "...excessively disproportionate..." Reference to federal law is unnecessary for most local projects where there is not federal aid at all. It is all local money, raised from our local taxpayers. Additionally, Congress is furiously debating the provision in the next Transportation Bill. The provision may not survive. But in any event what's the benefit of its inclusion in a "template". The document we are dealing with is a "suggested Template". It is not the policy itself. Keep it brief and simple! 4. Change the word "roadway" to "road" in line 2 of this Exemption. 5. Does this provision really belong in a "Complete Streets Template?" The policy deals with roads/streets, not with railroads! Under Section V Documentation.... 1. If you have the staff to do it, go ahead. 2. This is quite onerous on a County like Montgomery. Again, we build every year about o 37,000 linear feet of sidewalk at a cost of about $ 2.5 Million / year o We have a general bikeway program of about $500,000 per year o We spend over $1,300,000 per year in ADA retrofits and improvements o Our overall 6 year Capital Program is $ 105,820,000, or about $17.5 Million per year for the next six years. o All our road projects (6 year program of $358.8 Million or almost $60 Million per year) includes either a sidewalk, a bikeway or both. o Our Highway Maintenance Program for 6 year of Capital projects is in excess of $ 251 Million, or about $42 Million per year. And on and on... If you think that we are going to report annually or "periodically" to the TPB our efforts, we would need at least one full time person to prepare the reports. For what purpose? What is the relationship of the reporting to the "Complete Streets" effort? Can you think of another local jurisdiction in the region with this level of expenditures on the very issues that the Complete Streets promote? Furthermore, we have been doing these levels of expenditures in a mostly sustained way for the last 20 years. So, it is not new or a reaction to the new Complete Streets effort. So this provision in the policy is unrealistic. If you have staff to report, that is great. We would rather have our staff dedicated to implement projects that comply with the principles, than report it to the TPB for nothing.... 3. How do you proposed the implementation be measured? And who is supposed to do it. Do not impose requirements on the jurisdictions, unless you propose to give us the staff to do it. We all protest the federal government imposing "Unfunded Mandates". So, let's not go there at the regional level. In summary, the County is very supportive of the Complete Streets Template, (after all we have been doing it for more than 20 years) but it must be streamlined and reporting should not become onerous. Edgar Gonzalez, P.E. Deputy Director for Transportation Policy Montgomery County

	Adam Greenstein - 2/10/2012
Michael, Below, I have one additional comment on the draft resolution. “WHEREAS, Complete Streets will support efforts to reduce ground level pollution, greenhouse gas emissions, and decreases noise pollution…” – In conjunction with statements that discuss improved economic development in the vicinity of a Complete Street, there may be increases in localized greenhouse gas emissions and ground pollution, as well as increased noise from freight of all applicable types traveling to/from the area to supply the local businesses with their goods and services. Adam

	Tina Slater - 2/10/2012
Aside from the time it would take to update the database (and I recognize that I truly don't know how detailed & involved the update form is!), I think it's fine to "hurt other jurisdictions' feelings" --- let's go ahead and have a healthy & friendly competition about who can provide more miles of ped/bike access the fastest! --- Tina Slater, President Action Committee for Transit