December

21, 2018

Secretary Leslie Richards

PennDOT
400 North Street
Harrisburg, PA 17120

Dear Secretary Richards,

I am writing to ask that you direct PennDOT’s General Counsel to revise its 2017 decision that PennDOT
will not permit the installation of parking protected bike lanes on state roads.

This decision is impeding the installation of state of the art separated bicycle facilities in the
Commonwealth, thus negatively impacting public safety and incurring unnecessary expenses by
municipalities. PennDOT’s interpretation of Title 75 is inhibiting municipalities such as York, Pittsburgh
and Philadelphia from using this type of bike lane design, which is counter to the urgent need to better
protect bicyclists with state of the art bike lane designs.

We have four reasons why we think PennDOT should revise its decision and give municipalities the
flexibility to use the design.

First, bicyclist fatalities in Pennsylvania are rising. Bicyclists need better protection from facilities state
roads maintained by PennDOT. A review of traffic fatalities statewide over the past 20 years (1997-2017)
shows that the number of fatalities that are bicyclists has increased by 29%, while the number of
motorists killed dropped by 42%. In 2017, the number of bicyclists killed in the Commonwealth (22)
was the highest since 1998. Below is a graph of the percentage of fatalities that are bicyclists to
illustrate the increasing trend. We think this data makes the case that Pennsylvania must update its
policies so that PennDOT can use all proven safety designs to better protect bicyclists. Separated
bicycle lanes are a proven design that provide a higher level of safety than other types of bike lanes and
parking protected bike lanes are an attractive, low cost type of protected bike lanes. Protected bike
lanes are a proven design treatment that generates multiple benefits1,2

1
NITC-RR-583, 2014. Lessons from the Green Lanes: Evaluating Protected Bike Lanes in the U.S.
2
NYC DOT. 2014. Protected Bicycle Lanes in New York City.
1500 Walnut Street, Suite 1107 Philadelphia, PA 19102 P:215-242-9253 x 306 F:267-909-8726 1
WWW.BICYCLECOALITION.ORG SARAH@BICYCLECOALITION.ORG



Second, PennDOT’s decision constrains design options of municipal planners and designers who want
to use a proven safety design. Pittsburgh would have considered a parking protected bike lane for its
Third Street project, but did not because of PennDOT’s decision. York also had to change its TAP
application for its King Street project because of PennDOT’s policy. Limiting safety options for
transportation professionals is counterintuitive for a transportation agency. Federal Highway
Administration's (FHWA) supports taking a flexible approach to bicycle and pedestrian facility design3
and has published several guides to help fulfill the aim of its 2010 Policy Statement on Bicycle and
Pedestrian Accommodation Regulations and Recommendations4, including a Separated Bike Lane Design
Guide in May 20155.

3
USDOT FHWA August 20, 2013 memo on Bicycle and Pedestrian Design Flexibility
4
USDOT Policy Statement on Bicycle and Pedestrian Accommodation Regulations and
Recommendations Signed on March 11, 2010 and announced March 15, 2010
5
www.fhwa.dot.gov/environment/bicycle_pedestrian/publications/separated_bikelane_pdg/separatedb
ikelane_pdg.pdf
1500 Walnut Street, Suite 1107 Philadelphia, PA 19102 P:215-242-9253 x 306 F:267-909-8726 2
WWW.BICYCLECOALITION.ORG SARAH@BICYCLECOALITION.ORG



Third, PennDOT’s decision is costing municipalities financially. We offer the example of Parkside
Avenue in Philadelphia as a case where the City’s preferred design of a parking protected bike lane
would not be installed by PennDOT when it repaved the roadway because of PennDOT’s decision. An
alternative design had to be installed and the City of Philadelphia will have to incur additional costs to
install the parking protected bike lane design at a later date when the vehicle code language is “fixed.”

Fourth, this issue is a needless distraction when major issues about transportation funding need to be
worked out by the General Assembly and Wolf Administration. As you well know, all resources need
to be put to bear on helping the Commonwealth find solutions to the oncoming transportation funding
crisis. The issue about parking protected bike lanes should not be a distraction at this critical time.

Legislation (HB 1657 and SB 788) to fix this technical issue in the code languished in the Senate during
the last session despite full passage by the House on October 2, 2017. Pennsylvania’s residents should
not have to wait another year or two to have this issue resolved.

On behalf of the Bicycle Coalition of Greater Philadelphia, I am respectfully requesting that based on
these facts and circumstances, you direct PennDOT’s General Counsel to revise PennDOT’s 2017
decision regarding parking protected bike lanes to allow this proven safety treatment to be used by
PennDOT itself and municipalities on state roads.

I hope that this urgent policy issue can be prioritized and not become an unnecessary distraction in 2019
when there are so many other pressing transportation ssues that need attention.


Sincerely yours,

Sarah Clark Stuart
Executive Director


CC: Governor Tom Wolfe
Mayor Jim Kenney
Mayor Bill Perduto
Michael Carroll, Deputy Managing Director, City of Philadelphia

1500 Walnut Street, Suite 1107 Philadelphia, PA 19102 P:215-242-9253 x 306 F:267-909-8726 3
WWW.BICYCLECOALITION.ORG SARAH@BICYCLECOALITION.ORG



1500 Walnut Street, Suite 1107 Philadelphia, PA 19102 P:215-242-9253 x 306 F:267-909-8726 4
WWW.BICYCLECOALITION.ORG SARAH@BICYCLECOALITION.ORG