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Dear Commissioner Sheehan, Chair Sahr, and Ms. Marshall,
I write on behalf of the Lyme School Board and the Lyme School District regarding the Town of Lyme’s efforts with the New Hampshire Department of Transportation to install Rectangular Rapid Flash Beacons (RRFB) at the crosswalk between the Lyme School and the Converse Free Library on N.H. Route 10 (Union Street) in Lyme, New Hampshire. The Board and the District respectfully request that NHDOT and the Town immediately reconsider any decision to install RRFB at this crosswalk. The Board and the District also ask for the Federal Highway Administration’s guidance on whether FHWA’s approval of RRFB for optional use suggests, as the Town and State seem to claim, that RRFB would be an appropriate countermeasure to be deployed in these circumstances.
The Board and the District appreciate the NHDOT’s and Town’s efforts to improve safety along Union Street/Route 10 between the Lyme School, Converse Free Library, and Union Street residences. However, the Lyme School Board and the Lyme School District have serious concerns regarding the propriety of RRFB at this location and the lack of public process to date.
First, the Board and the District are concerned that there is insufficient evidence to support the practical use of RRFB as an appropriate countermeasure at this location. Given the geometry of the roadway, the existence of an overhead beacon, the number of driveways and side streets, the lack of a safe pedestrian route from parked cars to the crosswalk, and the menagerie of existing signage, the Board and the District believe that there are other actions and supplemental installations that could better convey and highlight a safe pedestrian crosswalk than RRFB and pose fewer potential adverse effects to District operations.
To date, the Board and District are not aware of any road safety audit or traffic, speed, or safety studies conducted by the NHDOT or Town along Route 10/Union Street that would support deployment of RRFB. The Board and the District respectfully request the NHDOT and Town to advise what evaluation safety assessment NHDOT and the Town performed to account for the characteristics of the roadway and evaluate crash history, speed data, driver yield rate, pedestrian traffic and use patterns, and the specific characteristics of this crosswalk, including District operations.
Second, FHWA guidance—particularly the Safe Routes to School program—seems to make clear that there are many other countermeasures that may be more appropriate for a rural two-lane highway that is a 20 mph school zone with manned crossing guards at school drop-off and pick-up and has no known documented history of high severity pedestrian crash risk. For example, this crosswalk has had faded or non-existent striping for some time and there exists no striping or signage, such as a yield bar or striped triangle, to indicate to a driver to stop for a pedestrian in the crosswalk and where to stop or yield. The Board and the District believe NHDOT and the Town should consider deploying durable high-visibility continental crosswalk striping, pare down extraneous signage, and post yield signage before concluding that safety justifies the expense of RRFB.
The Board and the District respectfully request NHDOT and the Town to state why other countermeasures were either discounted or not considered, including but not limited to a pedestrian hybrid beacon, crosswalk visibility enhancements, eliminating the shoulder and narrowing the crosswalk, sidewalk installation in the school zone to provide safe access to the crosswalk, or other countermeasures consistent with FHWA’s Guide for Improving Pedestrian Safety at Uncontrolled Crossing Locations and Safe Routes to School program. Put simply, Route 10/Union Street in Lyme is not an urban arterial route with documented high pedestrian crash data. The Board and the District respectfully request the NHDOT and Town provide data and justification supporting the NHDOT’s and Town’s decision to install RRFB at this location, including a rationale for how that decision complies with FHWA guidance and its interim approval of the optional use of RRFB.
Third, neither the Board nor the District have been included in any fact gathering or decision-making regarding this installation. The first step in the FHWA’s Safe Transportation for Every Pedestrian (STEP) program is to collect data and engage the public, and public involvement is also part of the NHDOT’s procedures. Given that District staff and students use this crosswalk frequently—indeed District staff work in both the school and library and man the crosswalk at school drop-off and pick-up—the Board and the District are concerned that RRFB was prescribed for this location without due consideration of the impact RRFB might have on District operations and the Lyme School (whose classrooms will face the RRFB), its staff, students, and the users of school facilities. The District is also concerned about the necessary mitigation that might be required to accommodate all students, and the Board and District are concerned about the use of RRFB at this location without first testing countermeasures that may be equally effective, less expensive, and have no apparent potential impact on District operations.
The Board and the District encourage the State and the Town to consider other countermeasures that may be more appropriate and less expensive for a rural two-lane state highway so close to an elementary school and library. The Board and the District also call on NHDOT and the Town to conduct appropriate safety and speed studies at the location and conduct a full and open fact gathering and decision-making process that accounts for all public input, including input from the Board and the District, the Converse Free Library, and the immediately affected property abutters, who have issued public statements that RRFB may adversely affect their documented epilepsy and photosensitivity medical conditions.
The Board and the District look forward to resolving this matter expeditiously through an open, fair, and fact-driven process that accounts for all input from stakeholders, including the Board, the District, the Converse Free Library Board of Trustees, affected property owners, and the public.
Jonathan R. Voegele, Esq. Chair, Lyme School Board