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Avenue NE Washington, DC 20002 VIA ELECTRONIC MAIL: email@example.com RE: South Capitol Street FEIS & Preferred Alternatives
Dear Mr. Dorsey: I am writing on behalf of the Washington Area Bicyclist Association (WABA) to address the South Capitol Street FEIS and the preferred alternative’s treatment of bicycling throughout the study area, which includes a new bridge across the Anacostia River, as well as significant portions of the District’s Wards six and eight. WABA would like to express its appreciation of the overall transportation concept: converting the bridge and surrounding area to an “urban boulevard” designed increasingly to accommodate non-motorists, such as cyclists and pedestrians. Further, WABA supports the incorporation of the 20 ft. multi-use trail on the bridge itself and the continuation of the multi-use trail along South Capitol Street east of the Anacostia River. Nonetheless, we would like to encourage the project team to better seize upon the opportunities presented by this $800M project to integrate facilities more fully to enable safe bicycling into the District’s transportation network. Existing conditions were identified as “lack*ing+ adequate facilities” (1-12) and “lack*ing+ regional roadway connections and facilities” (1-12), while “current bicycle routes are poorly marked, poorly maintained, and do little to create a network of bicycle facilities.” (1-14) Yet aside from the bridge itself, future improvements are proposed merely to “complement existing and planned bike lanes and trails” rather than taking the initiative to significantly improve, enhance, or create additional facilities spreading outward from the new bridge into the areas where people live, work, and play.
Not a single inch of bike lane is added with this $800M. Not a single protected lane or cycletrack is proposed. Not a foot of designated bicycle space is created. And of the three multi-use paths in the build alternatives, two are removed in this preferred alternative. The preferred alternative includes a bridge designed for the needs of the present and future, but leaves neighborhood connections insufficient for the existing modal mix, and grossly deficient to serve the modal mix for future growth and economic development of the sort that underlies this proposal. Viewed as a whole, this preferred alternative provides an incremental improvement to cycling in the District, but it is an increment dwarfed by the overall growth of cycling on both sides of the river. It is a measured step forward, when a leap would be needed just to maintain pace. Specifically, we are concerned with the following elements of the preferred alternative: Access through the Oval and Circle: While we do not object to the proposed oval or circle at each end of the Frederick Douglass Bridge per se, WABA is concerned that such facilities— especially at this scale—can present challenges for cyclists to safely navigate such intersections. The FEIS indicates no effort to ensure that these facilities are designed so that cyclists are able to navigate safely and effectively through these large, complex roadway features. Given the importance of these intersections to mobility through the entire project area, WABA asks that the FEIS include a clear statement that the traffic oval and traffic circle must be designed in a manner that is fully accessible to cyclists and provides safe access to and from trails, without relying on sidewalks or requiring cyclists to dismount. South Capitol Street: No dedicated cycling facility, such as a dedicated bicycle lane or cycletrack, is provided along South Capitol Street. Instead, cyclists are pushed to New Jersey Avenue as a north/south corridor, and bicycle-related improvements to South Capitol are limited to the inclusion of a 13’ curb lane. While the inclusion of a widened curb lane is an understandable intervention where no dedicated facility is to be included, a shared lane should measure a minimum of 14’ per AASHTO guidelines. The project team should provide compelling justification for failing to include designated space accommodating bicyclists on this vital transportation corridor. And, if a wide curb lane is to be substituted for dedicated space, it should not, under any circumstances, be narrower than fourteen feet of usable space, excluding gutters. New Jersey Avenue: Despite restoring a full 160 ft. of right-of-way to New Jersey Avenue, the preferred alternative allocates no space for cyclists in the form of a dedicated bicycle lane or cycletrack. Because no designated bicycle facility is included on South Capitol Street, cyclists are pushed to New Jersey as the alternate north/south corridor. Yet, despite its status as a “designated bicycle lane” and new 160’ of width, no cycletrack, bike lane, or other bicycle facility is included. Designated Bike Routes: Despite identifying existing bicycle routes and claiming to “complement” them, the FEIS proposes no facility improvement to any route within the area. This includes the section of O St. eastbound between Half Street, SW to South Capitol Street, where cyclists are instructed to enter and use the sidewalk to travel opposite westbound one-
way traffic. Forcing cyclists onto the sidewalk must be a last resort, and certainly no designated bicycle route should include such an instruction. Riding wrong-way on a sidewalk should not be part of any governmentally sanctioned bike lane. Contraflow lanes, cycletracks, or numerous other alternatives are available and should be implemented to allow for a legal connection that does not force cyclists to the sidewalk. Removal of Facilities in Ward 8: In Build Alternative 2, on which the preferred alternative was based, Firth Sterling Avenue, Howard Road, and Martin Luther King, Jr., Avenue would have received substantial improvements for cyclists. However, the cyclist-serving element of each is removed. o Firth Sterling Avenue: Both build alternatives under consideration included a multi-use path along Firth Sterling Avenue to improve multimodal mobility, complement the coming streetcar, and address the difficulties of bicycle-streetcar interactions in shared space. The removal of this trail creates conflicts between modes, undermines the goal of multimodal mobility that led to its initial inclusion, and makes cyclists less safe. A review of the public comments submitted reveals no significant public opposition to the path. Thus, WABA requests that it be included in the preferred alternative—or that the team’s rationale be provided for the decision to replace a facility designed to protect and enhance the mobility of multiple mode-users with one designed only for pedestrians. o Howard Road: Howard Road is a key multimodal connection, as it is the link from the Frederick Douglass Bridge to the Anacostia Metro’s rail, bus, and bikeshare options. Currently, the connection from the bridge to the metro station by bicycle requires some combination of wrong-way riding, curb jumping, and sidewalk riding. This is unacceptable, as such a significant connection must be made legal, safe, and accessible for bicyclists. In both original build alternatives, Howard Rd. was slated to become twoway and receive sidewalks. In the preferred alternative, the current, deplorable connection will remain unchanged. WABA asks that a legal, safe, accessible connection between the bridge and Howard Rd., as well as a safe means of traveling along Howard Road, be provided. The decision to not only make no connection for cyclists, but also to remove the proposed sidewalks for pedestrians, is contrary to the purpose and need of the project and should be rectified. o Martin Luther King, Jr. (MLK) Avenue: Like on Firth Sterling Avenue, a multi-use path was in each proposed build alternative to serve the project’s stated purpose of improving multimodal mobility. Again, the multi-use path was removed in the preferred alternative, with the project team choosing to create a facility designed to serve pedestrians rather than a path designed to accommodate multiple modes, including cyclists. And again, no rationale appears in the record for this decision to eliminate a facility that would improve multimodal transportation options and improve cyclist safety. WABA requests that the multi-use path, included in both build alternatives, be included in the preferred alternative.
In sum, WABA supports this big-picture redesign of the South Capitol Street corridor into an urban boulevard. The improvements to the multimodal capacity of the Frederick Douglass Bridge are significant and should not be understated, and the importance of the trail connection along South Capitol Street east of the Anacostia River is significant for allowing future connections within the regional trail network. However, we are disappointed that in much of the study area removed from the bridge itself, little attempt seems to have been made to integrate cycling into the overall transportation mix. Given the opportunity to create a long-lasting link between communities East of the River and West of the River in DC, the preferred alternative did little more than span the waterway, stopping short of connecting communities or taking bold steps to show that cyclists belong. So while we appreciate the improvements that are included, WABA is disappointed in the extent of the improvements throughout Wards six and eight. We hope that representatives of the neighborhoods that could benefit more from this project insist that improvements for cycling be made, opportunities for cyclists be embraced, and facilities for cyclists be included rather than ignored or hastily deleted. Sincerely,
Shane Farthing, Executive Director
Mayor Vincent Gray DDOT Interim Director Terry Bellamy Councilmember Tommy Wells Councilmember Marion Barry