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Item 2 Public Comment

Palo Alto City Council
December 1, 2025

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Item 2 Public Comment
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December 1, 2025
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Palo Alto City Council
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From: Ann Balin
To: Council, City
Subject: crosswalks on Stanford Avenue
Date: Monday, December 1, 2025 11:34:51 AM
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Dear Mayor Lauing & Council Members,
I am writing to ask that the department of transportation implement crosswalks to Stanford Avenue given your authorization. In a staff report from 2004 the PTC agreed that crosswalks are needed at Oberlin and Wellesley Streets. Yet these were not added.

Now traffic has accelerated greatly on Stanford Avenue. I am a resident of College Terrace and have witnessed friction on the avenue. Stanford Avenue is a main cut through from Junipero Serra to the El Camino Real. We have pedestrians crossing the avenue regularly.

The city needs to add more than just the two mentioned above. Right now there are crosswalks at Yale, Bowdoin Streets and another near Escondido School. It isn’t prudent to have only three on this busy corridor.

We need to keep residents and especially children safe as they cross Stanford Avenue.

Thank you for your consideration of these critically needed crosswalks.

Respectfully,
Ann Lafargue Balin

CMR:486:04 Page 1 of 5
TO: HONORABLE CITY COUNCIL

FROM: CITY MANAGER DEPARTMENT: PLANNING AND

COMMUNITY ENVIRONMENT

DATE: NOVEMBER 22, 2004 CMR: 486:04

SUBJECT: RECOMMENDED TRIAL IMPLEMENTATION OF THE

SELECTED TRAFFIC CALMING PLAN IN THE COLLEGE

TERRACE AREA

RECOMMENDATION

Staff recommends that City Council approve the following:

1. Adopt the project’s Mitigated Negative Declaration (Attachment H of staff report to the Planning and Transportation Commission);

2. Direct staff to implement the physical traffic calming device s shown on Plan A (Attachment B of staff report to Commission) on a trial basis in the College Terrace area; and,

3. Evaluate and report on the effectiveness of Plan A within one year of completion of its construction.

PROJECT DESCRIPTION
This project was i nitiated in response to a request signed by over 225 College Terrace residents who raised their concerns regarding cut -through traffic and excessive speeding.

The request was submitted to the City Council on September 27, 1999. Development of the College Terrace Traffic Calming Plan was funded by the Stanford University General Use Permit (GUP). Design and implementation of the Plan will be fully funded by the mitigations fund of 2475 Hanover Street. The Planning and Transportation Commission requested that the subject condition of approval be stated in the staff report to Council. The approval condition states: “The applicant shall pay the City the sum of $150,000.00 before commencement of new construction at 2475 Hanover Street to be used by the City to assist with traffic calming improvements in the College Terrace neighborhood.” This condition of approval (No. 11.4) was adopted by City Council on February 19, 2002.

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Following a comprehensive process of data collection, traffic analysis, identificatio n of alternative traffic calming plans and community consultation, the devices shown on Plan A (Attachment B of staff report to the Commission) were selected and are now recommended for trial implementation. The selected Plan does not include any additiona l closures and employs less restrictive physical traffic calming devices namely traffic circles, speed tables and raised crosswalks as listed below:
- Stanford Avenue: From east to west along Stanford Avenue, Plan A recommends a speed table west of Wellesley Street and a raised crosswalk just west of Oberlin Street. The Plan also recommends speed tables west of Amherst Street and Dartmouth Street.
- College Avenue: Four traffic circles at the intersections of College Avenue with Yale Street, Oberlin Street, Hanover Street, and Columbia Street. - Cambridge Avenue: A traffic circle at the intersection of Cambridge Avenue/Yale Street.
- California Avenue: A raised crosswalk at the west side of its intersection with Wellesley Street, and a speed table west of Princeton Street.

Detailed description of the College Terrace Traffic Calming Project, its background, performed analysis, developed alternative plans, and costs breakdown of selected alternative is provided in the staff report to Commission (Attachment B).

COMMISSION REVIEW AND RECOMMENDATIONS

The Planning and Transportation Commission reviewed and unanimously recommended the trial implementation of this project during the Commission’s meeting held on October 13, 2004. Minutes of the Commission’s meeting are provided under Attachment C.

Commission member Bonnie Packer requested that the staff report to Council note the following:

- Relevant section of the City’s Comprehensive Plan that illustrates consistency with the project; and,
- Performance measures to be emp loyed during the project’s trial period that are described in the Mitigated Negative Declaration (MND) document.

The City of Palo Alto Comprehensive Plan encourages the application of traffic calming.

Policy T -34 of the Comprehensive Plan states: “Implem ent traffic calming measures to slow traffic on local and collector residential streets and prioritize these measures over congestion management. Include traffic circles and other traffic calming devices among these measures.”

The recommended one-year trial period will be utilized to monitor the project in terms of its effectiveness and level of community acceptance, as well as in terms of any potential

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impacts and possible corrective measures. The MND developed for the trial implementation of this projec t (detailed in Attachment H of staff report to the Commission) covers performance measures controlling potential projects’ impacts as summarized below:

• With regard to short-term impacts during project’s construction, the MND identified mitigations covering truck movements to and from the neighborhood, construction hours, dust control and other construction specifications. • Pursuant to the guidelines of the Bay Area Air Quality Management District (BAAQMD), the project should not cause deterioration in the operational level of service of the two signalized intersections of Stanford Avenue/Escondido Road and Stanford Avenue/Hanover Street during either of the AM or PM peak hours. Should any significant deterioration is detected, appropriate corrective actio ns will be taken that could include improvements in signal timing and phasing plans. • In compliance with the City’s Neighborhood Traffic Calming Program (NTCP), the plan should not cause significant traffic diversion impacts on neighboring streets.

Significant traffic diversion is identified by a 25 percent increase in traffic volume on local and/or collector streets with “before” counts of less than 2500 vehicles per day (vpd), and more than 10 percent increase on local streets with a “before” count of 2500 vpd or greater. In the event that monitoring shows substantial traffic diversions, corrective actions will be taken that could be removing, relocating, or replacing one or more of the constructed devices.
• The traffic calming plan should not significantly impact response rates of emergency services. For example, travel times for Fire Department calls within and near the College Terrace neighborhood will not exceed the department’s mission goals of 4 minutes for 90 percent of fire and basic medical respons es, and 6 minutes for 90 percent of advanced medical responses (paramedics). Also, establishment of the recommended traffic calming devices should not increase the demand for police protection services nor substantially delay response times within the College Terrace neighborhood. The Police Department has a 3 -minute response time goal for emergency calls. In the event that monitoring shows substantial increases in response travel times, the necessary changes will be applied that could include removal, relocation, or replacement of one or more of the traffic calming devices contained in the Plan.

Additional Crosswalks

The Planning and Transportation Commission also requested that staff investigate the feasibility of establishing additional pedestrian/school crosswalks across Stanford Avenue, particularly at Wellesley Street and Oberlin Street. It should be noted that the establishment of a pedestrian/school crosswalk at an uncontrolled location could give pedestrians a false sense of security. Transportation staff typically establishes a pedestrian/school crosswalk at

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stop or signal controlled intersection approach. The establishment of a crosswalk could also be considered at a physical device (such as a refuge center median, or a speed table) constructed to increase motorists’ awareness/visibility of pedestrians and improve crossing safety.

From site observations, Stanford Avenue is an east -west collector roadway bordering the north side of the College Terrace area. This collector street has two vehicular tr avel lanes and bike lanes. Curb -side parking is allowed only on the south side of the roadway. A pedestrian sidewalk is also provided on the south side only. Pedestrian crosswalks across Stanford Avenue are established on the easterly and westerly legs of the intersection of Stanford Avenue/Yale Street, which is controlled by an all-way stop control. Marked school crossings of Stanford Avenue are provided on the easterly leg of the intersection of Escondido Road/Stanford Avenue and westerly leg of Hanover S treet/Stanford Avenue.

Both of the intersections of Escondido Road/Stanford Avenue and Hanover Street/Stanford Avenue are signalized. School crosswalks are also painted across Stanford Avenue on the easterly and westerly legs of its intersection with Bowdoin Street, which is controlled by an all-way stop control. Each of the intersections of Stanford Avenue/Wellesley Street and Oberlin Street/Stanford Avenue is a four-legged intersection with stop signs only on the two minor approaches (i.e., only on Wellesley Street and Oberlin Street, respectively).

During staff’s site evaluation, a considerable amount of pedestrian traffic to and from Escondido Elementary School was observed using the sidewalk on the south side of Stanford Avenue and crossing at the sign alized intersections of Stanford Avenue with Escondido Road and Hanover Street was noted. Some pedestrians also choose to cross Stanford Avenue at Yale Street, then travel along the frontage road that runs parallel to Stanford Avenue within the Stanford campus. This frontage road has two travel lanes with available side shoulders used for 90 degree angle parking. There is a paved sidewalk provided along the north side of this frontage road.

The Manual on Uniform Traffic Control Devices (MUTCD) indicates that crosswalks should be marked at intersections where there is a substantial conflict between vehicular and pedestrian movements. The MUTCD criteria for establishing an all -way stop control and associated analysis are provided under Attachment A.

It has been concluded from the performed MUTCD analysis that the establishment of an all- way stop control is not presently warranted at either of the intersections of Stanford Avenue/Wellesley Street, or Oberlin Street/Stanford Avenue. Consequently, without th e traffic calming plan, it is not recommended to paint pedestrian crosswalks across Stanford Avenue at these evaluated intersections. The requested crosswalks can only be considered if physical traffic calming devices are established at the intersections.

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ATTACHMENTS
A. Criteria and Analysis of All-Way Stop Control Based on Provisions of the Manual on Uniform Traffic Control Devices.

B. Staff Report to Commission, dated October 13, 2004 (including its attachments A– J).

C. Additional correspondence received from Mr. William D. Ross dated October 13 and November 1, 2004 (Mr. Ross’s concerns are addressed in the report to Commission and other attached documents).

Minutes of October 13 Planning and Transportation Commission meeting

PREPARED BY:

HEBA EL-GUENDY
Transportation Engineer

DEPARTMENT HEAD:______________________________________________

STEVE EMSLIE
Director of Planning and
Community Environment

CITY MANAGER APPROVAL:_______________________________________

EMILY HARRISON
Assistant City Manager

cc: Traffic Advisory Committee of the College Terrace Residents’ Association Palo Alto Bicycle Advisory Committee
City/School Traffic Safety Committee
From: Ann Balin
To: Council, City
Subject: Crosswalks in College Terrace
Date: Monday, December 1, 2025 11:12:17 AM
Attachments: WebPage.pdf
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https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes- reports/reports/city-manager-reports-cmrs/year-archive/2004/11- november/3967.pdf
From: Alan Wachtel
To: Council, City
Subject: Bicycle and Pedestrian Transportation Plan Update Study Session (Dec 1 meeting, Agenda Item 2) Date: Monday, December 1, 2025 8:14:18 AM
Attachments: Separated Facilities Discussion.pdf
Separated Bikeway Research--A Response.pdf
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i
Members of the Council:

The draft Bicycle and Pedestrian Transportation Plan Update that will be presented during your study session reflects the enormous time and effort that have gone into it, and it has many good points. But I want to focus here on areas where there is room for significant improvement. For reference, some of my concerns are set out in greater detail in the attached documents.

FYI, I'm a long-time member of the City's Pedestrian and Bicycle Advisory Committee (PABAC), but I'm not speaking here for the committee. I'm also a member of the Institute of Transportation Engineers, and I was a member of the California Bicycle Advisory Committee (CBAC), which advised Caltrans headquarters in Sacramento, from its formation in 1992 until it was dissolved in 2018. From 1999 to 2013, I served as CBAC's chair.

Roadways Are for All Users
The draft plan's proposals for bicycle infrastructure are limited almost exclusively to designated bikeways. But even the most optimistic scenario, in which the Complete Vision Network is fully built out at some distant future date, would provide bikeways on only about half of City streets. What about the other half? Cyclists will always have a significant need to travel on most of the remaining non-bikeway streets, because their origins and destinations often don't lie on designated bikeways. As long ago as 1978, Caltrans's "Planning and Design Criteria for Bikeways in California" found that "Probably the most important effort that could be undertaken to enhance bicycle travel would be improved maintenance and upgrading of existing roads that are used regularly by bicyclists, regardless of whether or not bikeways are designated."
And in fact, Palo Alto's Comprehensive Plan Policy T-3.5 already states, "When constructing or modifying roadways, plan for use of the roadway by all users." Other policies and programs set out, to a limited extent, how this is to be done, but much more could be added, in the Comprehensive Plan or elsewhere.

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The BPTP draft cites Policy T-1.19, to "Provide facilities that encourage and support bicycling and walking," but none of the other relevant policies and programs, notably Policy T-3.5. The update's lack of guidance for facilitating and improving bicycling on all roadways, not only designated bikeways, is a major omission that calls out to be rectified. Some possibilities not already enumerated in the Comprehensive Plan might include striping wide outside lanes or shoulders on busier streets, removal of on-street parking (granted that this is a politically sensitive issue), shared-lane markings, speed limits and traffic calming, signal timing, and roadwork and temporary traffic control. The plan should not only describe desirable policies, but indicate what procedures and workflows in the Office of Transportation, Public Works Department, or other bodies might be established to assure that these policies are carried out.

This approach would help to make the City bicycle-friendly everywhere, in both the short and long term, at relatively little cost.

Separated Bikeways
The draft's uncritical enthusiasm for Class IV separated bikeways--often, though misleadingly, referred to as "protected bike lanes"--should be replaced by a more balanced approach. It's true that the Council has shown a preference for separated facilities in the Safe Streets for All Safety Action Plan, in the grade separation project, on East Meadow Drive, on El Camino Real, and at a few other locations. It's also true that the Council has never been informed by the OOT that, despite the undeniable appeal of separated facilities, they raise substantial safety concerns, and the case for them rests on flimsy foundations.

The fundamental issue is that, for the most part, bicycles cannot be fully separated from vehicular traffic, because they necessarily interact at turning and crossing points. Separated facilities complicate this interaction. They typically require through bicycles to pass right- turning traffic at intersections and driveways on its right side, and right-turning traffic to turn at or near right angles from the left of and across the path of bicyclists overtaking on their right, in what for many drivers is a blind spot. This geometric conflict, often called a right hook, is a well-established cause of car-bike collisions and contrary to long-standing bicycle facility design guidance. A motorist would call it being cut off. It would never be employed to place right-turning vehicular traffic to the left of through traffic. This is not the only drawback of physically separated facilities, but it is a major one, and it will become even more acute with the increasing popularity of higher-speed e-bikes.

Car-bike collisions between intersections, on the other hand, which separated facilities might arguably help to protect against, are already relatively infrequent (as the BPTP Update itself shows).

I presented a thorough technical and historical analysis of this critical safety issue at the August PABAC meeting, and it's attached here as Separated Facilities Discussion.pdf. The lengthy discussion at that meeting included a presentation by Nick Falbo of Mobycon, one of the BPTP Update consultants, in favor of these facilities. (PABAC agendas and minutes are available at https://www.paloalto.gov/Departments/Transportation/Bicycling- Walking/Pedestrian-and-Bicycle-Advisory-Committee-PABAC.) Nick later provided further information in a memo titled "Protected Bike Lane Recommendations in the Palo Alto Bicycle and Pedestrian Transportation Plan," which appeared in the October PABAC packet. My response (which quotes Nick's memo in full for reference) was included in the November PABAC packet and is attached here as the file Separated Bikeway Research--A Response.pdf.

In brief, I found nothing persuasive in the studies Nick cited to support separated bikeways as typically designed, and I actually interpreted several of those studies as favorable to my position, rather than Mobycon's.

While I hope that the Council will at least look over these attachments to confirm that their arguments are well-grounded, I won't ask you to peruse them in detail or to make technical judgments that lie outside your domain. What you might reasonably do, however, is to request staff to respond to them--not just briefly and casually at your study session, but in writing, as a thorough, considered, substantive, responsive, and impartial review and evaluation of these concerns and their policy implications. This would need to be done by staff, not consultants (whose opinions are already fixed), and in a timely way that would allow potential changes to the updated plan before its adoption. You deserve to be fully informed on this central issue before making any decisions.

My recommendation would be that projects involving separated facilities be prioritized in the proposed network only where there is an identified problem that separation would help to address; that this objective could not otherwise be accomplished as effectively; and that whatever hazards the facility might introduce can be reasonably mitigated. This means I cannot endorse any of the high-cost near-term separated bikeway projects in Table 9 (p. 105) of the draft without further justification.

Respectfully,
Alan Wachtel
Palo Alto
Separated Bicycle Facilities: Innovative Comfort
and Safety, or Old Wine in New Bottles?
Alan Wachtel
PABAC, August 5, 2025

The draft Bicycle and Pedestrian Transportation Plan update represents a substantial investment of effort and contains many welcome observations and suggestions. In these comments, however, I intend to focus on a single more problematic issue. This plan, as well as the Safe Streets for All (SS4A) Safety Action Plan, the El Camino Real Bikeway project, the South Palo Alto Bikeways Project on East Meadow Drive, the VTA Bicycle Superhighway Implementation Plan, and several existing installations in the City depend on the appealing, widely popular, but, I believe, fundamentally misguided premise that bicycle safety can and should be promoted by physically separating bicycle traffic onto Class I bike paths or Class IV separated bikeways within or adjacent to busy roadways, including arterials. The BPTP includes many proposals for such facilities, regardless of the speed, frequency, or volume of crossing and turning traffic at intersections and driveways, and the conflicts created there, which receive no mention.

The BPTP draft quotes the Dutch cycling network design principles:

A safe bicycle network is one that creates a safe environment for all road users. When designing safe cycling infrastructure, it is important to minimize conflicts and minimize the negative outcomes of unavoidable conflicts between different roads users by striving to avoid differences in speed and mass as much as possible. At the street level this can be done by creating separated cycling infrastructure when cars are going at high speeds or traffic calming streets so that cars and bikes can mix safely.

The draft also states:

A protected bike lane is a dedicated facility for bicycles that is physically separated from motor vehicle traffic. Protected bike lanes should be implemented when cars and bikes are moving at different speeds, and it is unsafe for them to mix and share the same space. The updated bicycle network proposes 28 protected bike lanes. Protected bike lanes should be implemented on all arterials and high-volume collectors.

The SS4A plan that the Council recently adopted likewise includes the following policy: “Instead of a primary focus on shifting behavior through education campaigns or enforcement, it encourages roads, vehicles, and policies that are intentionally designed to prioritize safety.” That is, as much as possible, it relies on infrastructure to replace and compensate for user behavior.

This plan also states that “The City will also focus on projects that reduce exposure related risks by separating users traveling at different speeds or different directions with physical separation, to minimize conflicts and reduce the risk of crashes,” and refers numerous times to protected — 2 —

bike lanes or separated pathways facilities and the provision of protected bicycle facilities as safety measures. Separated facilities claim to “reduce conflicts between people biking and motorists. They also provide more physical protection that further reduces the risk of severe conflicts between bicycles and vehicles on the road.”
The premise of separation, appealing though it seems on the surface, directly contradicts prior design guidance (still in effect), traffic law, and collision statistics. In particular, this approach gives no attention to the speed, frequency, or volume of crossing and turning traffic at intersections and driveways, and the significant car-bike conflicts created there by such facilities.

It is often presented as new or innovative thinking, but in my opinion it more accurately represents old thinking from the 1970s whose lessons have been forgotten. If recent designs are to be credible and their use justified, these issues must be acknowledged and addressed directly. I hope this discussion will provide an opportunity for a direct response to the questions I raise, which Kittelson & Associates, a firm that helped to prepare several important design guides, as well as the ongoing BPTP Update, may be best qualified to provide. (A word on terminology. I take issue with the term “separated (or protected) bike lane.” The primary direction of these comments is to question whether such facilities are “protected” at all.

But it’s also misleading to refer to them as bike lanes in California, where bike lanes are designated Class II and separated bikeways are Class IV . This distinction matters, because California vehicle law requires bicyclists to ride in Class II bike lanes under certain circumstances, but not Class IV. It would be preferable to use “separated bikeway” or “cycle track,” the terms that appear in the Streets and Highways Code and the Highway Design Manual, or “separated bicycle facility” instead.

These legal considerations don’t apply in most states, so I don’t object to use by the Federal Highway Administration (FHWA) of the term “separated bike lane.” But it should be avoided in California.)
Over-reliance on separated facilities undermines the safety, efficiency, and mobility of experienced, transportation-oriented bicyclists. A comprehensive transportation system should include a full spectrum of bicycle facilities, including shared travel lanes, wide shoulders, Class II bike lanes (including buffered ones), elimination of on-street parking and with it the hazard of dooring, and bicycle boulevards.

What Does Separation Mean?
Because the concept of separated facilities figures heavily in the BPTP Update and so many other plans and projects, it deserves careful examination that it has not so far received.

To begin with, the idea of separation is far from novel. In fact, all traffic engineering separates users, in the basic sense that two users must not occupy the same space at the same time. It does this through a combination of geometric design, traffic control devices, traffic law, education, user behavior, and human factors.
— 3 —

Separation does not always, or even usually, need to mean a physical barrier. Longitudinal white lane striping serves to indicate travel paths for both motorized and nonmotorized traffic, and opposite-direction road users can be separated in space by yellow centerlines. Class II bike lanes, delineated by paint or cross-hatched buffers, are another example that demarcates preferential space for bicycle traffic. Less often, physical medians or channelizers are used, but we do not expect (and would be very surprised to see) physical barriers routinely separating same-direction lanes of vehicular traffic. And that might be because such separation, far from minimizing conflicts, has a very real potential to exacerbate them.

But, with certain exceptions, it is topologically impossible to maintain separation everywhere, or even for any extended distance. Traffic (of all varieties) needs to turn, to cross traffic moving or turning in other directions, to change lanes, and to merge. In other words, road users may have a need to occupy the same space, and this, too, is routine, so long as they do it at different times.

Stop signs and traffic signals at intersections, for example, accomplish the desired separation in time. So does the process of merging left or right (after yielding) to change lanes into a gap, in order to pass or in preparation for a turn.

The Safe Systems Approach often cites a redundancy or Swiss cheese model, in which holes (weaknesses) in one slice are mitigated by solid portions of adjacent slices. But slices cannot necessarily be considered independent. A change in geometric design, for instance, might be inconsistent with traffic law, habitual user behavior and training, or human factors. This interdependence must be taken into account, and the Swiss cheese model is best considered as a complement to traditional traffic engineering, not a replacement for it.

All this may seem like recapitulating the trivial and the obvious. The point is that separating road users is not by itself new. New approaches simply have their own theory of how it should be done, which is not integral to the concept of safety and should be examined critically on its own merits.

Channelization by Destination
One way traffic law provides for separation is by channelizing traffic into separate lanes. (The whole of Topic 403 of the Highway Design Manual is devoted to principles of channelization.) Between intersections, slower traffic keeps right and faster traffic passes on the left (and this applies equally to bicycle traffic, which is often, though not invariably, slower). At left and right turns, however, traffic is instead channelized by destination (and this also applies equally to bicycle traffic). Both the approach to a right turn and the turn itself, for instance, must by law be made as close as practicable to the right-hand curb or edge of the roadway (or in lanes designated by signs, signals, or pavement markings). And this is true even in the presence of bicycle lanes, which drivers of right-turning vehicles may (Vehicle Code §21209)—indeed, they must (§21717)—merge into within 200 feet of an intersection. Following the California MUTCD, bike lane stripes are typically dropped 50 to 200 feet before an intersection to facilitate this movement.
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There is one principal exception to these rules: Pedestrians receive physical separation in the form of sidewalks, onto which they’re channelized regardless of destination. Separated bike paths or separated bikeways adjacent to or within roadways treat bicyclists, in effect, as a species of pedestrian (they’ve been called “pedalestrians”) who are likewise channelized outside the vehicular stream (usually on its right side).

The unacknowledged design element common to most “innovative” bicycle facilities is that through bicycles must pass right-turning traffic at intersections and driveways on its right side.

This is true, for example, of Class I bike paths adjacent to roadways, Class IV separated bikeways, two-stage left-turn bike boxes, many (though not all) advanced stop line bike boxes, so-called protected intersections, and possibly buffered bike lanes (since whether and where turning motorists may merge into or cross the buffer has never been clearly defined, in either the California MUTCD or traffic law). It is not true of Class II bike lanes or shared roadways, where normal destination positioning and merging rules apply.

It would be extraordinary, however, to employ that same geometry for two lanes of vehicular traffic, which would never be designed to place right turns to the left of through traffic. Try to imagine striping a vehicular through lane to the right of a right-turn lane (except in rare cases where a traffic signal separates the movements in time). Now imagine it with a physical barrier separating the lanes. Does that seem like a reasonable design? Physical separation of road users has the potential to create new conflicts, which did not exist before, at every driveway and minor intersection. I’ll say it again—the casual use of this design for nonmotorized traffic demands to be carefully scrutinized. (It has other safety implications as well, but it will be enough to focus on this one.)
Sidewalks
Geometrically, Class I sidepaths and Class IV bikeways resemble sidewalk bicycling. They do have certain advantages over sidewalks: they aren’t shared with pedestrians, and they’re generally straight and smooth and lack street furniture. But they also allow and encourage much greater bicycle (or e-bike) speeds, and lead bicyclists to believe they have right-of-way at conflict points and need not take care, look around, slow down, or yield.

But pedestrians and bicyclists have very different operating characteristics, and do not necessarily benefit from similar facilities. Most pedestrians walk at 3 mi/h or less, and can stop or move backward or sideways within a single step. Many child bicyclists can travel at 10 mi/h; adults are often much faster, and e-bikes, which are rapidly gaining popularity among both adults and children, are capable (in the case of Class 3 e-bikes) of as much as 28 mi/h—comparable to cars, and exceeding most local speed limits. Greater bicyclist speed creates a far greater area within motorists must scan to avoid conflict, as well as less time to react.

Bikes, moreover, require a much greater distance to stop than pedestrians, and their maneuverability is very limited in comparison.
— 5 —

It’s easy to see that many bicyclists love to ride on sidewalks: bikes on sidewalks are a commonplace sight, even on quiet streets or on roads with bicycle facilities. These bicyclists almost surely feel more comfortable on the sidewalk, where they undoubtedly believe they’re safe from cars. It’s not surprising that they might also prefer a sidepath or Class IV cycle track that resembles a sidewalk, especially one that is expressly promoted as separated or protected.

But it has been firmly established for many years that sidewalks are not generally suitable for bicycles. Bicycling on sidewalks, especially adjacent to busy streets, though it might feel safe, is frequently more dangerous than on the adjacent roadway, because of unexpected conflicts, often with poor sight lines, with crossing and turning traffic at driveways and intersections, at locations where neither party expects or can easily see the other. There are many studies to this effect (including my own). A primary conflict (though not the only one) goes by the familiar name of right hook: a right-turning car cuts off and collides with a through bicyclist on the right. This is also a common collision type on the roadway. “Innovative” design types have an inherent potential to create and intensify the same type of conflict, with the same false sense of security.

Prior Design Guidance
Prior design guidance (still valid, and still in effect) cautions against this geometry. For instance, the Highway Design Manual states:

Index 1003.1: Please note, sidewalks are not Class I bikeways because they are primarily intended to serve pedestrians, generally cannot meet the design standards for Class I bikeways, and do not minimize vehicle cross flows.

Index 1003.1(5): Intersections are an important consideration in bike path design.

Bicycle path intersection design should address both cross-traffic and turning movements. If alternate locations for a bike path are available, the one with the most beneficial intersection characteristics should be selected.

Index 1003.1(7): Bike paths immediately adjacent to streets and highways are not recommended. While they can provide separation between vehicles and nonmotorized traffic, they typically introduce significant conflicts at intersections. . . . They are not a substitute for designing the road to meet bicyclist’s mobility needs. Use of bicycle paths adjacent to roads is not mandatory in California, and many bicyclists will perceive these paths as offering a lower level of mobility compared with traveling on the road, particularly for utility trips. Careful consideration regarding how to address the above points needs to be weighed against the perceived benefits of providing a bike path adjacent to a street or highway. Factors such as urban density, the number of conflict points, the presence or absence of a sidewalk, speed and volume should be considered.

Index 1003.3(2): Wide sidewalks that do not meet design standards for bicycle paths or bicycle routes also may not meet the safety and mobility needs of bicyclists. Wide — 6 —

sidewalks can encourage higher speed bicycle use and can increase the potential for conflicts with turning traffic at intersections as well as with pedestrians and fixed objects.

The California Manual on Uniform Traffic Control Devices (CA MUTCD) says (Section 9C.04):

Standard:
06 A through bicycle lane shall not be positioned to the right of a right turn only lane or to the left of a left turn only lane.

Support:
07 A bicyclist continuing straight through an intersection from the right of a right-turn lane or from the left of a left-turn lane would be inconsistent with normal traffic behavior and would violate the expectations of right-or left-turning motorists.

Guidance:
10 Posts or raised pavement markers should not be used to separate bicycle lanes from adjacent travel lanes.

Support:
11 Using raised devices creates a collision potential for bicyclists by placing fixed objects immediately adjacent to the travel path of the bicyclist. In addition, raised devices can prevent vehicles turning right from merging with the bicycle lane, which is the preferred method for making the right turn. Raised devices used to define a bicycle lane can also cause problems in cleaning and maintaining the bicycle lane.

While the facilities discussed in those sections are not necessarily identical to the ones being promoted and proposed, in many cases they are analogous, and the guidance provided above should be considered carefully.

Caltrans Design Information Bulletin (DIB) 89, “Class IV Bikeway Guidance,” which is directly applicable, notes that intersections (both major and minor) and driveways present significant issues:

Intersection crossing points offer unique challenges to the design and operation of a separated bikeway. [T]he usability and safety of the separated facility depends heavily on the manner in which intersections, driveways, and alleys, as well as pedestrian facilities, interact with and connect to the separated bikeway and bikeway network. The bikeway must provide adequate visibility at intersections, driveways, and alleys, to avoid right or left hook collisions in which vehicles turn in front of bicyclists traveling straight.

As such, it is critical that careful thought and planning go into the design of all intersections, driveways, and alleys located along a bikeway.

The FHWA publication “Separated Bike Lanes on Higher Speed Roadways” notes that “Driveways that intersect with separated bicycle lanes create a potential crash risk due to the conflict between turning motor vehicles and through-bicyclists.” — 7 —

DIB 94
Advocates of separated facilities, however, do not generally cite these design principles. They prefer to rely on Design Information Bulletin 94, “Complete Streets: Contextual Design Guidance,” which recommends Class IV bikeways on high-speed, high-volume roads—exactly where the conflict with crossflows may be greatest. This recommendation is summarized in a graph on p. 23, whose source is unattributed. The foundation for this deviation from previous (and unrefuted) guidance remains mysterious and impossible to evaluate.

During the external review of the DIB 94 draft, I made the following comments (among others about the frequency, speed, and volume of crossflows):

The enthusiasm shown in these guidelines for Class IV separated bikeways almost entirely neglects—as is typical—their critical weakness: the unnecessary geometric conflicts (commonly known as right hooks) that they create at crossflows such as intersections and driveways (conflicts that would unequivocally never be designed into vehicular lanes). These conflicts can be (but are not always) mitigated at major intersections by providing merging areas or separate signal phases (at the cost of delay and possible noncompliance), but that cannot be done at every minor intersection and driveway, where the conflicts remain. The same considerations are true, to a lesser extent, of Class I bike paths.

Unlike Class II bike lanes, where turning vehicles can merge safely across the bike lane stripe in advance of the turn (as required by law), separated bikeways force vehicles into an almost 90-degree turn, while bicyclists overtake in their right rear blind spot at full bicycle speed, expecting to have right-of-way. Meanwhile, parked cars, shrubbery, or other devices used as separators often obstruct sight lines.

The token measures suggested in design guides are inadequate to mitigate these conflicts, and are treated as an afterthought, rather than a built-in consequence of the facility. Instead, the ability to minimize or mitigate these geometric conflicts should be treated as an essential element of facility selection from the very beginning. [A facility selection list] omits the most critical factor: frequency, speed, and volume of crossflows at intersections and driveways.

Individual responses to external review comments were not provided, but the final DIB does not mention the term “crossflow” or any variation or synonym that I can find. The only mentions of “conflict” in connection with Class I or Class IV facilities involve buses and their passengers.

My concerns were not addressed, even to dispute them.

There is good reason to believe that Kittelson was involved in creating this draft of DIB 94, and would be well placed to justify it and to answer questions about it. — 8 —

In response to the Phase 2 draft of the BPTP prepared by Kittelson, I commented in 2024: “DIB 94 unaccountably neglects the importance of minimizing and regulating crossflows on separated bikeways,” and cited DIB 89 and HDM Index 1003.1(7), as quoted above. The consultants’ response was simply “Noted.” There was no attempt to engage with the issues I raised. No other comment received such a perfunctory response.

Another commenter (it might also have been me) observed: “Broadside collisions are the most frequent type of bicycle collision that occurred in Palo Alto within the five year study period.

This statistic indicates that to prevent collisions, intersections and other crossing and turning locations should be the focus, segments between intersections less so.” To this the response was “Agreed.” Yet separated facilities provide separation between intersections (where it is needed less), while not only failing (unavoidably) to provide separation at intersections (where it is needed more), but exacerbating the conflict at those points. How does this contribute to safety? This is an essential question.

The BPTP draft found that broadside collisions are the most frequent type of bicycle collision that occurred in Palo Alto within the five year study period. The Safety Action Plan reported that broadside crashes were among the highest percentages of KSI crashes. (The SS4A statistics are hard to interpret, however. They don’t seem to differentiate among types of road users. It also isn’t clear whether this category includes car-bike right-hook collisions, though the definition, “between two vehicles on conflicting paths where the front of one vehicle contacts the side of another,” implies that it might.) This plan notes that on Walk & Roll Routes crossing higher stress streets, 99 percent of crashes occurred at intersections.

These statistics indicate that to prevent collisions, intersections and other crossing and turning locations should be the focus, rather than segments between intersections. Yet separated facilities provide separation between intersections (where it is needed less), while not only failing (unavoidably) to provide separation at intersections (where it is needed more), but actually exacerbating the conflict at those points. How does this contribute to safety? This is an essential question.

Are Mitigations Possible?
What mitigations do advocates of these facilities propose for intersection and driveway conflicts? They have not entirely neglected the question. For instance, NACTO has released a publication called “Don’t Give Up at the Intersection,” and its “Urban Bikeway Design Guide” contains a section on intersections. The section on cycle tracks (in California also known as Class IV bikeways) advises in part:

Driveways and minor street crossings are a unique challenge to cycle track design. A review of existing facilities and design practice has shown that the following guidance may improve safety at crossings of driveways and minor intersections:
— 9 —

If the cycle track is parking protected, parking should be prohibited near the intersection to improve visibility. The desirable no-parking area is 30 feet from each side of the crossing.

For motor vehicles attempting to cross the cycle track from the side street or driveway, street and sidewalk furnishings and/or other features should accommodate a sight triangle of 20 feet to the cycle track from minor street crossings, and 10 feet from driveway crossing.

These distances are far less than the up to 200 feet provided for Class II bike lanes. They result in a sharp, nearly 90-degree turn across the bicycle facility—that is, a right hook; a motorist would consider it being cut off—rather than a merge into it.

The FHWA “Separated Bike Lane Planning and Design Guide” (which Kittelson & Associates also helped to prepare) correctly notes that:

It is not possible to maintain permanent physical separation of bicycles and automobiles through intersections, where cross street and turning movements must cross the path of bicyclists. Intersections are where most bicycle-vehicle collisions occur, and where riders feel the most stress. Designers have implemented a variety of strategies, including both time- and space-separation, for maintaining the benefits of separated bike lanes through intersections.

One method of doing this is through separate bicycle signal phases. That method can work, but as I noted in reviewing the DIB 94 draft, it introduces delay for all modes, which may in turn raise issues of compliance. (Bicyclists are not known for strict adherence to traffic control devices, and many motorists seem baffled by the concept of no right turn on red.) In any case, this method does not extend to STOP-signed and uncontrolled intersections and driveways, which are generally much more numerous.

Another often-proposed mitigation is the so-called protected intersection. I fail to see, though, what about this design is protected, other than its name. It only shifts, not resolves, the point of conflict. (If this intersection design and geometry, coupled with physical barriers between adjacent lanes of traffic, are felt to be so desirable in reducing conflicts, why aren’t we applying them to vehicular traffic as well?) But even taken at face value, this design also has applicability only in limited locations and is not a general solution.

This guide also suggests shifting through bicycle traffic laterally to the left of the right-turn lane before vehicles can move right, which is a more conventional approach that I see as consistent with standard engineering practices. There are further proposals that would take too much time to go into here, without changing the overall conclusion.

The FHWA “Separated Bike Lanes on Higher Speed Roadways” (which Kittelson again helped to prepare) recommends separate signalization, “protected” intersections, and setback crossings.

I’ll simply point out again that these treatments are at best applicable only at certain locations, not generally.
— 10 —

This guide also says that “Crossings on higher speed roads should be as short and infrequent as possible, with vertical protection extended for as long as possible.” I find the second part of this statement astonishing. Extending the separation as long as possible prevents merging and increases the conflict, not reduces it.

What all these discussions have in common, however, is that they implicitly treat intersections as, at most, residual areas that cannot be separated or “protected,” where bicyclists and motorists must unavoidably interact. Improving those interactions is treated as an enhancement. What they do not acknowledge or address is that new geometric conflicts, created by the bike path or separated bikeway itself, may very well pose greater hazards than the less frequent midblock conflicts that might be ameliorated.
90-Degree Turns vs. Merging
Furthermore, no matter how successfully special facilities might somehow manage to resolve turning conflicts at intersections and driveways, they train bicyclists to pass right-turning traffic on the right, and motorists to turn right from bicyclists’ left, without merging, as a general rule at all locations—everywhere, not just at special facilities (the traditional right hook). These are dangerous practices that should not be encouraged. However, it seems possible that proponents regard these behaviors as a feature, not a bug, that should indeed be practiced everywhere. They may consider 90-degree turns to be as safe as, or safer than, merging. (In 2024 there was actually an unsuccessful bill to that effect in the California Legislature.) So it might be helpful here to set out certain key differences:
 A merging driver can change lanes at a time and place where it’s safe to do so, rather than at a fixed location. A driver who is prevented from merging into a bikeway is forced to slow down or stop close to the turning point.
 When merging, the relative speed between car and bike, which are both moving, is lower, making it possible to accept a smaller gap. If the driver slows or stops, it increases the closing speed of overtaking bicyclists—which e-bikes will only worsen, and which motorists often underestimate—who are also led by these designs to understand they have right-of-way and can pass at full speed. This higher relative speed makes it harder to find and judge an adequate gap for turning.
 Turning drivers must scan a much greater distance to the rear for bicyclists than they are accustomed to with pedestrians. Underestimating bicyclists’ (or e-bicyclists’) speed will result in inadequate scanning.
 Merging into a new lane is a routine driving skill that drivers perform many times a day.  Many motorists, depending on vehicle design, headrests, cargo, rear window size, roof pillars, and sideview mirror adjustment, may have a blind spot in the area where a bicyclist is approaching, assuming they’re aware of the presence of bicyclists at all. The blind spot is also relevant when merging, but a merging driver can continue in motion and wait a second or two for any traffic to move out of the blind spot. A driver who’s waiting to turn from a fixed location sees shorter gaps and may be less patient.  Turning sharply places additional cognitive demands on drivers, who must now scan for rapidly overtaking bicyclists on the right, in addition to any potentially conflicting traffic — 11 —

from other directions, all at once, instead of in stages. In the process, these drivers may overlook pedestrians approaching from the opposite direction.

In fact, p. 7 of the SS4A plan identifies 90-degree-angle conflicts between motorists and bicyclists of all ages as a safety focus area, based on crash data analysis, community input, stakeholder feedback, and systemic risk analysis. Why, then, propose to create so many more of them? P. 34 identifies improper turning as among the most common primary injury risk factors.

Why encourage more of it?
The Effect of Separated Facilities
It is not enough to simply declare who has right-of-way, whether through education, signage, or even traffic law. The party who must yield must actually be able, in a practical sense, to see and yield to the traffic that’s given right-of-way. Yes, I understand—cyclists are virtuous, cyclists are vulnerable; that doesn’t change sight lines or speeds. Drivers properly bear much of the responsibility, but they can’t be assigned all of it. Bicyclists, like pedestrians, have their own responsibilities, must have appropriate skills, and must stay alert. Separated facilities don’t necessarily benefit the casual or less experienced bicyclists they’re meant to attract; those cyclists are just less likely to recognize their deficiencies. The rapidly growing popularity of e- bikes only emphasizes these concerns.

The effect of separated facilities, it seems to me, is to provide comfort and the perception of safety, rather than its reality. In addition to their geometric conflicts, physical barriers also create a nontrivial crash risk (they’ve been known to cause severe injuries), and two-way separated facilities introduce all the well-known hazards of wrong-way travel, which I can’t see as somehow mitigated by being intentional. Still, it might be contended that separated facilities, despite their manifold drawbacks (were they to be acknowledged), should nonetheless be provided, on an optional basis, for bicyclists who prefer them, with anyone else free to continue using the roadway.

This argument, however, overlooks important points. The cross section occupied by the separated bicycle facility and barrier will likely result in the remaining roadway lanes being too narrow for bicyclists and motorists to share comfortably side by side (as they might have formerly). It will be intimidating, even for experienced bicyclists, to ride in a narrow lane on a higher-speed roadway. And motorists who expect bicyclists to keep to their designated facility, out of their way, might not take kindly to being delayed. Bicyclists who dare to ride in the roadway risk harassment, at least by honking, and the most antagonistic drivers might tailgate or pass too closely. Do Safe Streets for All (for “travelers of all ages and abilities”) and the BPTP include a commitment to preserve the rights of bicyclists who prefer, for reasons I’ve detailed at great length, to continue riding safely and efficiently on the roadway—for instance, by routine installation of the BICYCLES MAY USE FULL LANE sign (p. 100) on roads with separated facilities, and education of motorists and law enforcement officers that bicyclists may lawfully do so, whether or not there is such a sign?
— 12 —

The City of Cupertino provides an instructive example of the unintended consequences of separated facilities. No doubt with the best of intentions, raised islands have been installed along many streets popular with bicyclists to create separated bikeways. As a result, bicyclists are confined within a narrow channel bounded by the crash hazards of the island on the left and the curb on the right, with barely enough lateral space for shy distance from either (plus the issues of passing, road debris, and irregular surfaces inside the channel). These islands extend to within a few feet of intersections and driveways, forcing bicyclists and motorists into right-hook conflicts at every such point.

Even leaving aside the risk of motorist harassment, there are few gaps between islands where bicyclists can leave the facility and merge into a left-turn lane. Instead, they have to make do with two-stage left-turn bike boxes, which are confusing—they may mislead bicyclists into turning left in a single movement, without yielding to traffic overtaking in the original direction; introduce delay; and may expose bicyclists to yet another right-hook conflict on the cross-street.

The net effect of this design is a regression toward the bad old days of mandatory sidepaths.

Though sidepath use may no longer be legally required—assuming law enforcement officers understand that, which is not a given—the roadway, thanks to the presence of a separated facility, narrow traffic lanes, and impatient motorists, has been made hostile to bicycling. For those who recognize their hazards, it is no longer possible to bicycle safely or comfortably on those streets.

Palo Alto should resolve not to follow Cupertino’s example.

The Bottom Line
Let me reiterate that, for all this lengthy discussion, my question is ultimately a simple one. What is the basis for believing, contrary to long-standing engineering practice for both vehicles and bicycles, that it is safe, much less desirable, for through bicycle traffic to pass right-turning vehicular traffic on its right side? Where, when, and how have proponents of separated facilities recognized and addressed this fundamental issue?
The appendix examines the historical origins of recent guidance and its compatibility with traffic law. This history turns out to have Palo Alto connections. — 13 —

Appendix: What Are the Origins of This Reversal?
What are the origins of the sudden reversal in bikeway design guidance? The following discussion is lengthy and of secondary importance to engineering questions, so those with limited time may treat it as optional. But it does help to explain the current state of affairs.

Chronologically, the turning point was the 2011 National Association of City Transportation Officials (NACTO) “Urban Bikeway Design Guide,” which was followed by the FHWA “Separated Bike Lane Planning and Design Guide” (2015) and “Separated Bike Lanes on Higher Speed Roadways” (2024); Caltrans Design Information Bulletins 89, “Class IV Bikeway Guidance” (first issued in 2015) and “Complete Streets: Contextual Design Guidance” (2024); similar publications in several other states; and, most recently, the fifth edition of the American Association of State Highway and Transportation Officials (AASHTO) “Guide for the Development of Bicycle Facilities” (2024).

But this history is only descriptive. The NACTO Guide did not develop from a comparative assessment of various bicycle facilities; the Request for Proposals had already determined the treatments to be included.

Psychologically, the appeal of bikeways that are “protected” or “separated” from motor vehicles; that claim to be suitable for all ages and abilities (implicitly including little or no ability); that enable infrastructure to take the place of user behavior; and that place any responsibility that might remain entirely onto the drivers of motor vehicles is difficult to resist. Little wonder that such bikeways should prove so popular, with planners and designers as well as users. But of course I don’t propose to psychoanalyze bicyclists or transportation professionals here. What I’m interested in is the technical foundations of these approaches. (By the way, wouldn’t the ideal method be to design roadways for motorists of all ages and abilities? Why don’t we just do that?)
Light was unexpectedly shed on these questions—both the turnabout in design guidance, and the reluctance of its proponents to confront doubts—by an article in the March 2025 ITE Journal, published by the Institute of Transportation Engineers. As I mentioned above, I consider these not so much new ideas as old ones recycled from the 1970s and long since superseded. But I didn’t realize that this account is, in fact, literally true.

In “The AASHTO Bike Guide Sets a New Standard for Safe, Comfortable Bikeways,” Bill Schultheiss of Toole Design, who was project manager for the guide, and his co-authors stress comfort as their priority. It’s right there in the title, and I count the words “comfort” or “comfortable” occurring eleven times in the article. Of course this is an admirable goal, but it should not come at the expense of safety. It’s no secret that the authors and I would disagree about the resultant safety of the designs.

Under the subhead “Everything Old Is New Again,” the authors write:
— 14 —

[T]he promise and value of bike lanes is not a new idea.

In 1972, two analyses out of California suggested a new way of thinking about bikes: a study by De Leuw, Cather & Company that analyzed the performance and safety of the nation’s first bicycle network in Davis, California, and a report from UCLA that reviewed national and international research on bikeway planning and design. These studies found that both bicyclists and motorists preferred streets with bike lanes, and that separated bike lanes improved safety (although they may require additional maintenance and parking restrictions).

In 1974, AASHTO published the first national guidance for bicycling in the United States, which recommended designs that will look familiar:
 Continuous bike lanes on streets
 Marked bicycle crossings
 Two-stage turn queue areas or boxes
 Offset geometry of bike lane to manage turning vehicle conflic ts These elements are visible as illustrated in Figure 7 of the 1974 Guide.

The continuous bike lanes in the figure extend unbroken along the curb and through the intersection, or else are offset onto the sidewalk and crosswalk or an adjacent crossing in advance of the intersection. The caption describes these as “now known as separated bike lanes and protected intersections.”
The De Leuw, Cather study treats a right-turning car that makes its approach to the intersection in the bike lane as a “deliberate encroachment” on the territory of the bicyclist. In other words, a geometric conflict at right turns is assumed to be necessary and unavoidable. It likewise considers a bicycle that leaves the lane approaching an intersection in order to execute “an unauthorized form of left turn” a deliberate encroachment by the bicyclist. It’s no surprise, then, that its recommendations do not allow for bicyclists (or motorists) following traffic law; no such options are even presented.

Even so, this report finds protected lanes to be appropriate only in very specialized situations.

The UCLA report seems to be the source of the Class I, II, and III bikeway terminology (later augmented by IV) now confined almost exclusively to California. Its discussion of intersection design is aligned with what Schultheiss et al. describe, but that seems to follow necessarily from an implicit assumption in both reports, never expressed outright, that bicyclists must always hew closely to the curb for their own safety. As in the De Leuw, Cather study, no alternatives are examined or compared. The only occurrences of the word “merge” or a variation are in other contexts.
— 15 —

As for the safety of separated bikeways, the report reviewed several European studies, one of which found that:

At intersections, the investigators reported that fewer accidents occurred to bicyclists and moped drivers when there were cycle tracks; and for one-way tracks the decrease approximated 30%. In these cases physical barriers between the road and the track prevented cyclists from carelessly moving towards the left before they reached the intersection so as to make a left hand turn. On the other hand, and consistent with later Danish findings; chances of a vehicle colliding with a cycle while making a right hand turn onto the minor road, slightly increased when a track was provided. The investigators however, concluded that the net result of providing cycle tracks was beneficial.

This is a weak conclusion at best, and the authors observe that none of the studies were subject to statistical testing, that no firm inferences can be drawn, and that any recommendations cannot be generalized beyond the studies themselves. In any case, “carelessly moving towards the left before they reached the intersection so as to make a left hand turn”—also a concern of the De Leuw, Cather study—would not, I hope, be viewed today in so negative a light. Again, this study’s designs are incompatible with bicyclists following traffic law.

Why did the De Leuw, Cather and UCLA studies, and the 1974 AASHTO Guide that relied on them, not become the basis of subsequent practice? Because, to put it melodramatically, in this Garden of Eden there lurked a serpent. Schultheiss, of course, words it differently:

But in the late 1970s, these ideas faced backlash. Bicyclists feared they would lose their right to bicycle in travel lanes; concurrently, the transportation industry deemed separating bikes from cars impractical. A philosophy known as “vehicular cycling” emerged, based on the premise that few people would bicycle, and that those who did should operate essentially as motorists and share travel lanes. . . .

The vehicular cycling approach was adopted into national guidance, impeding the development of American bicycling infrastructure for nearly 50 years. Now, we’re returning to the evidence-based approach we glimpsed in 1974. Informed by robust research and urban bikeway experimentation that has occurred over the last 15 years, the new AASHTO Bike Guide marks the beginning of a new era.

I’m sure that many people seeing this can already read well enough between the lines. But Schultheiss and two other authors make their argument explicit in a Transportation Research Board paper from 2018 titled “A Historical Perspective on the AASHTO Guide for the Development of Bicycle Facilities and the Impact of the Vehicular Cycling Movement.” After Davis, California, became the first community in the United States to build a network of bike lanes, a new brand of bicycle advocacy – vehicular cycling (VC) – formed to oppose efforts to separate bicyclists from motorized traffic based on fears of losing the right to use public roads. Via positions of power and strong rhetoric, vehicular cyclists influenced design guidance for decades to come. . . . — 16 —

I’m curious what positions of power this refers to—political? professional? The only power I’m aware of that vehicular cyclists have ever possessed is the persuasive one of knowledge, experience, logic, analysis, and persistence.

In 1972, the City of Palo Alto, CA, began to implement a bicycle network by installing unprotected bike lanes and signed bicycle routes – including sidewalk bike routes, and created an ordinance requiring the use of bike lanes.

I remember these early bike lanes. At a time when there were no widely accepted standards and no uniform regulation, they were marked by an obscure dark-green stripe that was universally disliked. There were also sidewalk bike paths along Middlefield and Embarcadero. Palo Alto enacted an ordinance requiring use of both on-street and sidewalk bicycle facilities (as cities in those days were permitted to do).

Since there were no exceptions to mandatory bike-lane use, through bicyclists came into conflict with right-turning motorists at intersections. I remember seeing a handout—a utility bill insert, maybe?—cautioning that in this situation no one had right-of-way, and everyone needed to be careful. That ambiguous advice was quickly found not to work, and there is no reason to believe it would work better now. It was also unclear how bicyclists were to turn left.

This attracted the attention of John Forester, a local engineer and amateur bicycle racer.

It attracted Forester’s attention because he lived in South Palo Alto and commuted to work in Menlo Park by bicycle along Middlefield Road. (I should disclose right here that I knew John Forester well personally. I visited his home in Palo Alto many times (before he moved to Sunnyvale, and then Southern California), and worked with him on bicycle issues for years. I also received certification from him as an Effective Cyclist and an Effective Cycling Instructor.) Concerned about the mandatory use ordinance and the potential to be required to bicycle on narrow sidewalks with pedestrians, he became involved with the California Statewide Bicycle Committee, which was tasked with developing proposals to modify legislation and create bikeway standards.

Here the authors confuse two different committees: the Statewide Bicycle Committee, which was primary concerned with legislation (which Forester was indeed a member of) and the later Statewide Bicycle Facilities Committee, which dealt with bikeway standards (which he was not a member of). More about these committees below.

Forester believed bike lanes would increase risks associated with turning motorists, motorists opening doors from parked vehicles, and bicyclists turning left, and, most importantly, delegitimize a bicyclists’ right to operate on a street.

Forester’s safety concerns were entirely reasonable ones. And his fear of losing the right to bicycle on the road was well-founded, given the restrictive ordinances in Palo Alto and many other locations. The Vehicle Code to this day retains a mandatory bike lane law (though modified with many exceptions, thanks largely to the good work of the Statewide Bicycle Committee). — 17 —

And bicyclists’ right to the road faces recurrent danger again today, less now as a matter of law and more as a matter of in fact:
 The very concept of “separation” as the ultimate goal might suggest that shared roadways are undesirable, and that accommodating bicycling on them should carry at best low priority.
 As mentioned earlier, the right-of-way needed for Class IV bikeways usually results in the general traffic lanes becoming too narrow to share side by side, and intimidating even to experienced and confident bicyclists.
 Aggressive policing of the roadway by even a few territorial motorists can lead to harassment of bicyclists, especially when Class IV bikeways are misleadingly referred to as bike lanes (whose use is mandatory).

Despite extravagant promises to accommodate all ages and abilities, experienced cyclists receive scant attention in current bicycle planning. They are often classified as “strong and fearless” (in a set of arbitrary categories that, though widespread, have no empirical validation), as if only the young and foolhardy would dare to brave the roadway.

To prove protected bike lanes were dangerous, he rode his bicycle at roadway bicycling speed on a sidewalk designated for bicycle use and attempted to turn left across all lanes of traffic from the sidewalk at this speed. He published his account of this ride as “the one valid test of a sidepath system” that proved sidepath style bikeways were “about 1,000 times more dangerous than riding on the same roads.” While this account was clearly anecdotal, Forester used this experience—as well as his position as an engineer—to claim sidewalks, sidepaths, and protected bike lanes were dangerous and would increase liability for designers and cities in the event of a crash.

Here, for comparison, is what Forester wrote in his first publication on the subject, in Bike World magazine in 1973:

The sidewalk is dangerous: even a brisk pedestrian rarely walks faster than 2.5 mph, while average cyclists do 10-12 mph. It’s like putting 18-mph cyclists on a 70-mph freeway. Furthermore, there are no rules of the sidewalk—anybody may walk in any direction he chooses, stop, start, and turn anywhere. I know of two pedestrian fatalities caused by cyclists already—one in San Jose a month ago and one reported by a friend in Minneapolis. And cars cross the sidewalk everywhere. A car emerging from its hedge- lined driveway may be quite safe for pedestrians, who travel slowly and stop in one step, but it is highly unsafe for cyclists. At intersections the same rule holds—the motorists are supposed to stop for crosswalk traffic, but they never allow for anything faster than a pedestrian.

This sounds, and is, indignant, but its observations remain perfectly reasonable.

These events inspired him to author a book titled Effective Cycling, which centered on a philosophy that “bicyclists fare best when they act as, and are treated as, drivers of — 18 —

motor vehicles.” The book explains his methods for driving his bicycle in a manner similar to a motorized vehicle, a concept he later popularized through articles in Bicycling Magazine. . .

First of all, that should properly read vehicles, not motor vehicles or motorized vehicles. The difference matters. No one imagines that bicycles are as large, as heavy, or as powerful as cars; bicyclists are also far more vulnerable than motorists, and most of the time they’re slower (though nowadays even younger riders can operate e-bikes at speeds comparable to cars on local streets).

Under Vehicle Code §670, a vehicle is a device by which any person or property may be propelled, moved, or drawn upon a highway. All such devices, regardless of their other characteristics, are subject to the rules of the road in Division 11. For historical reasons, that section goes on to exclude devices moved exclusively by human power. But §21200 effectively undoes that exclusion by granting bicycle operators all the rights and subjecting them to all the responsibilities of drivers of vehicles.

In other words, what Forester advocated, far from a radical, elitist proposition, was only what traffic law has always required. His contribution was to analyze, codify, and disseminate how bicyclists could and should do this do this more thoroughly than anyone before him.

Without access to the paper copies of 1970s studies Forester critiqued (only recently available via the internet), transportation professionals, public agency staff, and citizens who were unaware of research contradicting Forester’s claims had few sources other than his books for bicycle planning. . . .

But this statement is inconsistent with the next paragraph, which describes a much more influential document. The authors trace most bicycle planning and design guidance from 1978 until relatively recently to Caltrans’s “Planning and Design Criteria for Bikeways in California.” Under the direction of California Statewide Bicycle Facilities Committee, a new design guide was developed between 1975 and 1978.

In this they are correct: this guidance was highly influential. But they are wrong to view this so negatively or its development as biased.

The work of the committee was heavily influenced by Forester, who was now president of the California Association of Bicycling Organizations. . . . The two primary references for the 1978 CalTrans Guide were Munn’s 1974 ASCE paper and Forester’s Cycling Traffic Engineering handbook.

I’m uncertain where this claim came from. Those sources constituted only two of the 16 references appended to the guide. Among the others were the De Leuw, Cather study, the UCLA study, and the 1974 AASHTO guidelines. So those publications were hardly overlooked during the development process.
— 19 —

To explain further, I need to go into the history of this committee.

Planning and Design Criteria for Bikeways in California The “Planning and Design Criteria for Bikeways in California,” adopted by Caltrans on June 30, 1978, to be effective September 1, were indeed highly influential in the field of bikeway planning and design. This was a standalone publication whose contents were later incorporated into the Caltrans Highway Design Manual and the California Manual on Uniform Traffic Control Devices, where much of that guidance remains to this day. The 1981 AASHTO “Guide for Development of New Bicycle Facilities” also drew heavily on California’s recommendations, sometimes nearly verbatim, as did subsequent editions of the AASHTO guide (the name varies slightly over the years), as the TRB paper goes on to describe in some detail.

Its influence may have been the result of the painstaking and transparent manner in which this publication was developed by the Statewide Bicycle Facilities Committee, as part of a study authorized by the Legislature. The committee was chaired by Rick Knapp of Caltrans (later a long-time Caltrans district director) and consisted of a diverse set of members:
 Rick Blunden, representing the League of American Wheelmen (later known as the League of American Bicyclists); Rick later became Chief of the Caltrans Office of Bicycle Facilities when it was reinstated in the early 1990s  Merick Chaffee of the California Department of Parks and Recreation  David Pelz, representing the League of California Cities and long-time traffic engineer for the City of Davis
 Richard Rademacher of the California Highway Patrol
 James Ray of the California Traffic Control Devices Committee; as traffic engineer for the County of Sacramento, he’s best known for inventing the two-way left-turn lane  Lloyd Roberts, representing the County Supervisors Association of California (later known as the California State Association of Counties)
 John Finley Scott, representing the California Association of Bicycling Organizations (also Forester’s organization—and, to be fair, mine); he was a sociology professor at U.C.

Davis
I have copies of minutes of most of the committee’s meetings. In addition to those meetings, which were open to the public, two well-advertised meetings were held, one in San Francisco and one in Los Angeles, from 10:30 a.m. to 4:00 p.m. each, to solicit public comment on a draft of the report. Comments were also accepted by mail. Among the attendees and commenters at the Northern California meeting were Joan Thompson (who preceded Gayle Likens with the City of Palo Alto) and Ellen Fletcher, representing the Santa Clara Valley Bicycle Association (now known as the Silicon Valley Bicycle Coalition).

In the minutes of several, though not all, committee meetings, John Forester is listed among ten or so advisors to the committee (which only means interested parties). He gave a presentation at the September 14, 1977, meeting, as did Jim Ray, traffic engineers from Santa Clara County, and traffic engineers from the City of Cupertino. It’s clear, however, that Forester’s opinion did not — 20 —

carry disproportionate influence; in his own report of this meeting, which I also have, he noted that “I attach a copy of my proposed section on planning which was rejected without discussion by the committee.”
I’ve looked through the minutes for topics related to bike lane marking and right turns or to separated bikeways and found these:
 In a slide presentation on existing bicycle facilities in the United States, Europe, and Africa, some “of questionable geometrics and design” and others “of high standards,” one observation was that “Dikes on the outside edge of bike lanes should be avoided where not required as they collect debris. Dave Pelz stated that the City of Davis has removed dikes where they were used to separate autos and bicycles. They were determined to be a hazard to both motorists and bicyclists (presently contrary to Section 21717, CVC).”  Among “Some Design Details to Consider in Study” was “Striping configuration at through intersections (conventional intersection).”
 Proposed revisions to an early draft document included “Strong recommendation against bike paths immediately adjacent to roadways.”
 “The use of raised bars, dikes on bike lanes—It was concluded that the standards would include a mandatory prohibition against the use of raised barriers to delineate bike lanes because they prevent right turning motorists from merging into the lane in accordance with the Vehicle Code; they prevent bicyclists from exiting the bike lane when necessary to turn left or avoid hazards in the bike lane; and they represent a hazard to bicyclists and motorists.”
These notes reveal why it was inevitable that the committee would recommend dropping or dashing bike lanes in advance of an intersection. It wasn’t the result of rhetoric or pressure; it was to comply with traffic law. In particular, §21717 of the Vehicle Code, which became law in 1976, reads: “Whenever it is necessary for the driver of a motor vehicle to cross a bicycle lane that is adjacent to his lane of travel to make a turn, the driver shall drive the motor vehicle into the bicycle lane prior to making the turn and shall make the turn pursuant to Section 22100.” I’m not aware of any other states that have laws precisely like this, but Vehicle Code §22100 (as cited just above) provides that “Both the approach for a right-hand turn and a right-hand turn shall be made as close as practicable to the right-hand curb or edge of the roadway,” with specified exceptions. This has been the law in California at least since 1939; a similar provision was added to the Uniform Vehicle Code (a national model code) in 1930, and the laws of all fifty states and the District of Columbia, with some variation, are in conformity. The only exception I could find is that Wisconsin Statutes §346.31(2) also provides: “If, because of the size of the vehicle or the nature of the intersecting roadway, the turn cannot be made from the traffic lane next to the right-hand edge of the roadway, the turn shall be made with due regard for all other traffic.”
It’s also important to note that the merging operation must observe §21658(a): “A vehicle shall be driven as nearly as practical entirely within a single lane and shall not be moved from the lane until such movement can be made with reasonable safety.” — 21 —

Schultheiss et al. quote disapprovingly the following statement from the 1978 Caltrans guidelines, calling it “a remarkably different view of bicycling from the research conducted to date”: “Most of these roads are sufficient to accommodate shared use by bicyclists and motorists, and hence, most bicycle travel has occurred and will continue to occur on that system.” This statement remains in the Highway Design Manual to this day, in slightly modified form (Index 1002.1): “Most bicycle travel in the State now occurs on streets and highways without bikeway designations and this may continue to be true in the future as well.” It adds, “In some instances, entire street systems may be fully adequate for safe and efficient bicycle travel, where signing and pavement marking for bicycle use may be unnecessary. In other cases, prior to designation as a bikeway, routes may need improvements for bicycle travel.” The HDM also contains (or cross-references) extensive guidance about the planning and design of bikeways of all classes. It would seem unexceptionable that most streets will not be designated as bikeways; that bicyclists, whose origins and destinations, like motorists’, can lie almost anywhere, need to travel on many of those streets for at least part of their trip; that those streets should therefore be suitable for and accommodate bicycle travel; and that both bicyclists and motorists need to understand how to share the road safely and courteously. But Schultheiss et al. seem wary of any street that does not include a bikeway. (On the other hand, Schultheiss et al. cite favorably Anne Lusk’s misinterpretation of the work on sidewalk bicycling that Diana Lewiston and I published in 1994. But I’ll leave that discussion aside for now as too much of a digression.)
SCR 47 Committee
So, to be thorough, we should also inquire into the origins of §21717, even though it merely emphasizes what is already required by traffic law. The answer is that it can be traced to another committee with a similar name, the Statewide Bicycle Committee—also known as the SCR 47 Committee, because it was created in 1973 by the Legislature’s Senate Concurrent Resolution 47 to study problems related to bicycling in California and to review the Vehicle Code and recommend changes that would benefit both bicyclists and motorists. I ought to list this committee’s membership, too (it has some overlap with the other committee:
 Dick Rogers, Caltrans, Chair
 Barbara Bania, Office of Traffic Safety
 John Forester, California Association of Bicycling Organizations  Neil Good, State Senate
 William Owen, League of California Cities
 Manuel Puentes, Automobile Club of Southern California  Merick Chaffee, Department of Parks and Recreation
 Lloyd Roberts, County Supervisors Association of California  Jim Swatsenbarg, California Highway Patrol
Forester was indeed a member of this committee, but it, too, had a diverse makeup, and he was the only bicycle advocate represented. There is also a ten-page list of advisors (interested parties — 22 —

who could provide valuable information). Among those named are Ellen Fletcher; Dave Uggla, a long-time member of PABAC; and Ted Noguchi (traffic engineer for the City of Palo Alto). This committee’s work, too, was a thorough, comprehensive, and transparent process. It held public meetings in Redding, San Francisco, Fresno, Santa Barbara, Los Angeles, San Diego, and Sacramento, attended by a total of about 800 people.

Most of the committee’s recommendations were quickly added to the Vehicle Code. One of them was this: “When necessary to make a right hand turn on a roadway which has a bicycle lane to the right of the motor vehicle lane, the motorist must merge into the bike lane in accordance with Section 21658 and make his turn as close as practicable to the right hand curb or edge of the roadway in accordance with Section 22100.”
This, with minor changes, became §21717. (See above for the content of the cross-referenced sections.) I think it is important to cite the committee’s reasoning: “It is the Committee’s opinion that inconsistent local rules of the road . . . cause confusion and lead to additional conflicts at intersections. For this reason the Committee recommends that motorists be required to merge into the bike lane and make a right turn in the usual manner as close as practicable to the right- hand curb or edge of the roadway.”
Is Vehicular Cycling Elitist?
Forester’s detractors often misrepresent his views, and that is the case here. Earlier I quoted Schultheiss as saying, “A philosophy known as ‘vehicular cycling’ emerged, based on the premise that few people would bicycle, and that those who did should operate essentially as motorists and share travel lanes. . . .”
In a description of his book, however, Forester claimed the contrary: “Rather than a book for experts, as many people originally described it, Effective Cycling is a book that can show every beginning cyclist how to ride in the way that is best for him or her.” He even developed a training course for upper elementary and middle school students (I’ve taught this course myself).

This is far from elitist.

I’ve already dealt with operating as “motorists.” Moreover, vehicular cyclists are taught to share travel lanes only when they are too narrow to share side by side, and then only when the speed differential is relatively low.

Forester could be charming in person, but he was a very ineffective advocate for his beliefs. He was famously argumentative, abrasive, and impatient with and intolerant of those who he thought didn’t see as clearly as he did. He had the influence that he did because of the power of his ideas, not his personality, rhetoric, or insistent voice.

From reading distorted accounts of vehicular cycling, you wouldn’t realize that Forester emphasized, above all else, respect for traffic law (barring a few discriminatory exceptions) and cooperatively sharing the road with all other users, motorists, bicyclists, and pedestrians alike.

This framework of order, regularity, and predictability, far from being, as some people seem to — 23 —

see it, an imposition on bicyclists’ freedom or an attempt to control them, is actually highly protective.

Also contrary to the way he’s often depicted, Forester was a great believer in science, experimentation, and evidence. He conducted many observations of road users on his own, and zealously analyzed whatever material on bicycle operation and safety he found published (and here I’ll agree with Schultheiss and others that there has been far too little of it). He might at times have overstated his case, and he had little use for subtlety or tact, but he was always to be taken seriously.

Other Contemporary Commentary
Rick Knapp, the Caltrans engineer who chaired the Statewide Bicycle Facilities Committee, presented a paper titled “An Effective Bicycle Program: More Than Paths, Stripes and Signs” to a transportation conference in Oakland in 1978, at the time the committee’s work was in its final stages, describing the personal insights his work on the committee had given him into typical approaches to bicycle planning. These observations remain particularly apt:

A large percentage of work on bicycle facilities to date has been counterproductive—has caused more problems than it solved. . . .

The agencies that address the “bicycle problem” usually seek the solution that will make bicyclists disappear. They develop bikeway master plans and programs designed to get bikes off the road—at least off the roads where cars are apt to be. . . . Some do this because they believe this is the only safe place for bicyclists to ride. Others do it because they believe this is where bicyclists want to ride. Far too many do it because they do not want bicyclists interfering with the flow of auto traffic in major transportation corridors . . .

Agencies addressing the “bicycle problem” become very frustrated when they find that many bicyclists avoid their bikeways in making their trips. These bicyclists are looked upon as dissidents by the local agency and many motorists (who take credit for paying for the highways and the bicycle facilities). . . .

Local organizations usually view bicycling organizations as radical interest groups—and they usually are. They are viewed as representing only elitist bicyclists and are not considered a valid sounding board for proposals intended to the serve the general public. . . .

Many bicycling organizations have actively opposed bikeways in general because of the bad experiences they have witnessed. . . .

Yes, it’s true. Everything old is new again.
— 24 —

It is important to recognize that there are less than 2,000 miles of bikeway in California compared with 130,000 miles of road. Obviously, the utility bicyclist cannot get around without using the road system.

This ratio has surely improved since 1978, but the disproportion remains. The road system is crucial.

A year later, Alex Sorton, a senior transportation engineer with Northwestern University’s Traffic Institute and chair of the ITE committee on bicycle facilities, wrote in “Bicycle Facility Standards: Designing for Tomorrow with Obsolete Information” in Bicycle Forum magazine:
“The AASHTO Guide to Bicycle Routes was a useful document at the time it was developed in 1972. Since then, however, much of it has become obsolete as better and more complete information has become available.”
He continued, “Some of the design alternatives discussed in the Guide have been found not desirable.” One of those he listed was the use of curbs or parked cars as buffers between the bike lane and the outside travel lane, which “creates more problems than it solves, such as motor vehicle-bicycle conflicts at intersections caused by parked vehicles’ shielding the bicyclists from motorists’ view.” Another was the channelization of bicycle traffic through intersections.

Among the features Sorton looked for in a new guide being developed by the FHWA was “independent bikeways that complement the existing roadway system . . . and that do not require bicyclists to operate in a manner contrary to the rules of the road.” He recommends as the most current state of the art the Caltrans “Planning and Design Criteria,” which “has been developed using current research, operational experience and input from the total bicycling community.” In Conclusion
As Sorton says, those early bikeway design guides were thorough, professional efforts that were valuable in their day, and much of their guidance has stood the test of time. But certain designs implicitly assume that bicyclists will not and must not, for their own safety, follow vehicular traffic law, and the renewed popularity of these designs is in part a backlash against an erroneous conception of vehicular cycling.

These early publications are not rediscovered long-lost manuscripts, containing the wisdom of the ancients, and they have not been suppressed by an elitist but vocal minority. If guidance has changed, it might be because lessons have been learned, though it might also be that sometimes those lessons are forgotten and must be learned again.

Separated Bikeway Research: A Response
Alan Wachtel
November 4, 2025, PABAC Meeting

At the August PABAC meeting, I questioned the safety and utility of physically separated bikeways, which form a significant portion of the draft Bicycle and Pedestrian Transportation Update, the Safe Streets for All Safety Action Plan, the El Camino Real Bikeway project, and several other local projects or plans. (These facilities are also known as cycle tracks, Class IV bikeways, or commonly but incorrectly, as separated or protected bike lanes. “Protected” is a subjective term that I take issue with (though others might disagree), but objectively they are not bike lanes, which are designated as Class II bikeways in the California Streets and Highway Code, the Caltrans Highway Design Manual, and the California Manual on Uniform Traffic Control Devices. This distinction matters in California and should be carefully observed, because Class II bike lanes create legal obligations that Class IV separated bikeways do not.) My concerns about separated bicycle facilities are detailed at length in Attachment 1 to the August PABAC agenda. There is no need to repeat them all here, but the fundamental issue is that this design (as well as Class I bike paths adjacent to roadways; two-stage left-turn bike boxes; many, though not all, advanced stop line bike boxes; so-called protected intersections; and, depending on interpretation, buffered bike lanes) requires through bicycles to pass right-turning traffic at intersections and driveways on its right side, and right-turning traffic to turn at or near right angles from the left and across the path of bicyclists overtaking on the right. This geometric conflict, often called a right hook, is a well-established cause of car-bike collisions and contrary to all previous bicycle facility design guidance. A motorist would call it being cut off. It would never be employed to place right-turning vehicular traffic to the left of through traffic. This is not the only drawback of physically separated facilities, but it is the major one.

The lengthy discussion at that meeting included a presentation by Nick Falbo of Mobycon, one of the BPTP Update consultants, in favor of these facilities, which appeared as Attachment 2 to the August agenda. I told Nick at that time that I’d appreciate evidence supporting the safety of separated bikeways. He replied in the form of a memo to Ozzy Arce, dated September 10 and titled “Protected Bike Lane Recommendations in the Palo Alto Bicycle and Pedestrian Transportation Plan.” Nick cited a number of studies, which he thoughtfully provided copies of (with one exception, discussed below). Nick’s memo and the full text of the studies constituted Attachment 2 to the October PABAC agenda.

I thank Nick for providing this information, which I will respond to here. I’ll distinguish Nick’s memo by quoting it with a gray background.
— 2 —

Memo

To : Ozzy Arce, City of Palo Alto

From : Nick Falbo, Mobycon Inc.

Date : Sept 10, 2025

Subject : Protected Bike Lane Recommendations in the Palo Alto Bicycle and Pedestrian Transportation Plan

Mobycon recommends protected bike lane facilities on many roadways in the City of Palo Alto as part of the update to the Bicycle and Pedestrian Transpiration Plan. These recommendations are in alignment with national guidelines and are made with the intent to improve comfort and safety of people riding bicycles.

As explained above, I prefer to avoid the misleading term “protected bike lane.” Please consider that comment to apply to all further occurrences.

As I contended in my earlier memo, comfort—which is a subjective judgment heavily influenced by framing and experience—seems to have superseded safety as the primary facilities criterion. It’s true that a number of guidance documents (listed in my August comments) make recommendations along the lines that Nick suggests. But those guidelines do not seem to have developed from a comparative assessment of various approaches to bicycle facilities. Instead, as I observed then, they appear to rely on an idealization of early 1970s design guidance, which assumed implicitly that bicycles should travel near the curb and motorists would necessarily turn across their path at near right angles—an unstated principle that also seems to govern current guidance favoring separation. This nostalgia was combined with a revisionist history of bicycle facility design, which I earlier refuted in detail, in order to reject long-standing prior guidance.

I’m looking for the foundation that the guidelines Nick prefers should rest on: reasoning, evidence, experiments, or data to support these design choices. That’s what Nick’s memo is meant to provide.

Note that many of the studies cited were conducted before the recent dramatic popularity of e-bikes (as, of course, was other earlier research, including my own). The substantially greater speed of many e-bikes, compared to most pedal bikes, increases the area in which motorists need to scan for them and reduces the time available to react. These differences may call for reassessment on all sides.

The following memo documents key studies exploring the safety of protected bike lane facilities, also known as Separated Bike Lanes or Cycle Tracks. This list is not exhaustive but can provide some context for facility selection and design.

In-road crashes matter

Many concerns about protected bike lanes have to do with the potential for crashes at intersections.

This is important, and much research and guidance are focused on understanding and mitigating — 3 —

these risks. It is also important to consider the risks of conflicts where motor vehicles overtake or pass a bicyclist in the roadway. Research from the UK found that the most common cause of fatal bicyclist collisions in urban areas is overtaking (McCarthy, Gilbert, 1996).

I agree that overtaking crashes are a significant crash type (one that many bicyclists fear) that deserve careful attention. However, this study does not support the claim that they are the most common type (which Lusk et al., cited below, also make, citing the same source). With limited data available, the researchers tentatively concluded that the most common cause was left turns (corresponding to U.S. right turns), in 34 out of 86 fatalities to which causes could be assigned. Being hit from behind was second, with 22.

The draft BPTP Update dated October 2025 reports that in Palo Alto in the five years from 2018 to 2022, “The most commonly-cited collision types for bicyclist-involved collisions were broadside collisions (61%) followed by sideswipe collisions (13%). For fatal and severe injury bicycle collisions specifically, the most common collision types were broadside collisions (54%), followed by head-on and hit object collisions (15% each).” The most commonly cited primary collision factor for bike-car collisions in general, and for fatal and severe injury collisions in particular, was improper turning. Overtaking or hit-from-behind crashes were not mentioned.

Protected bike lanes largely prevent overtaking crashes.

Protected bike lanes protect users within the protected segments of the facility, eliminating an entire subset of vehicle-involved crashes that occur within the roadway or bike lane during overtaking events.

Yes, agreed. But nothing in the U.K. or Palo Alto data suggests that there would be a net benefit to preventing overtaking crashes with physical separation at the expense of complicating bike-car interactions at intersections and driveways, where the majority of crashes (turning and broadside) are known to occur.

Looking at both overtaking and intersection crashes, a study of cycle tracks in Montreal found that the injury rate for cycle tracks was 28% lower than in the street. These were all bidirectional cycle tracks and the study acknowledged that one-way configurations would likely have been safer (Lusk, 2011).

The study by Lusk et al. has been widely cited, but also widely criticized, including on methodological grounds. John S. Allen, the author or co-author of many publications about bicycling, including Bicycling Street Smarts, which has been adopted as the bicycle driver’s manual in several U.S. states, summarizes this criticism on his blog:
“Flaws of the study include describing stretches of paths in parks and away from streets as cycle tracks; including stretches which had not been built yet in the reported mileage; selecting a multi-lane comparison street 10 blocks away with heavy, faster traffic for comparison with a cycle track street which is small and has light, slow traffic; examining short stretches which end just short of busy intersections; giving the length of one of the paths as twice as long as it is, halving its reported crash rate, and neglecting injuries to pedestrians.” Allen’s blog page includes links to a very lengthy, detailed rebuttal of Lusk’s study and to another negative review of it.
— 4 —

Lusk’s study also misinterprets the work that Diana Lewiston and I published in ITE Journal in 1994. For reasons of space, I’ll defer discussion of that issue to another time, but let me say briefly that Lusk’s analysis estimated the number of midblock collisions, rather than relying on observational data; her conclusion was not statistically significant; and she failed to account for a statistical phenomenon known as Simpson's paradox.

Most drivers don’t look before turning

Researchers in the University of Toronto's Faculty of Applied Science & Engineering studied the eye movements of drivers at busy Toronto intersections and found that more than half failed to make necessary scans for pedestrians or cyclists at right turns. (Kaya, et al. 2018).

This finding supports measures to improve conspicuity before the turning maneuver, as well as increased visibility within and after the turn.

The authors of this study begin by summarizing another study: “An in-depth analysis conducted in Finland found that cyclist-car crashes occurred most commonly when the driver was turning right. Only 11% of these drivers noticed the cyclist before impact, whereas 68% of the cyclists noticed the driver and most of them thought that the driver would give way as required by law. The drivers were identified to be misallocating their attention because they were looking left for vehicle traffic.” The disparity here between driver and bicyclist expectations helps to explain why right turns across a lane of bicycle traffic so often result in conflict, but looking to the left is standard (and often necessary) driver behavior at a right turn. If the driver had instead moved safely into the bike lane in advance of the intersection, the merging behavior (looking right and to the rear) would have been decoupled from the turn (looking left).

In the Toronto study, the bike lane was physically separated from the roadway, and drivers were compelled to turn across it at near right angles. At one intersection out of the two studied, the parking lane that provided the physical separation seems to have obstructed sight lines. At the other, four out of the six failures were due to participants entirely failing to check the bike lane for cyclists behind. This may not be surprising, considering that the interaction between drivers and bicyclists is concentrated at a single conflict point, and drivers may tend to focus there, rather than behind them for approaching bicycle traffic.

The graphic in Nick’s memo illustrates just this point:

Exhibit 2A from the MassDOT Separated Bike Lane Planning and Design Guide illustrates how a wide separation from the travel lane provides space to see bicyclists during the turning maneuver.

— 5 —

Notice that even with an offset, bicyclists are visible to motorists looking ahead only within a narrow cone.

Faster bicyclists or those on e-bikes might well approach the conflict point from outside the driver’s range of vision.

Another graphic from the MassDOT Guide, which Nick did not include, is instructive:

Though it’s labeled as a conventional bike lane, a Class II bike lane would permit drivers to merge into the lane, and bicyclists to move out of it, to avoid conflict, behavior that differs from what’s shown. This graphic more closely resembles the geometry of a physically separated bikeway, and illustrates the inherent risk of a right hook. The bicyclist is completely out of sight of drivers who only scan ahead.

Wide buffers increase safety

A study from the Netherlands found that increased separation between the bikeway and the roadway can improve safety over immediately adjacent bike lanes. Separating the bike lane by 6.5 to

15.5 ft through an intersection allows drivers to yield to people bicycling during a right turn movement (Schepers, 2011). The study theorizes that his design decreases the complexity of the driving task in that it offers drivers turning into the side road extra time to notice cyclists.

Raised crossings increase safety

The same study found that raised bicycle crossings have a large effect on drivers’ behavior and were effective in reducing the number of bicycle crashes at priority intersections by decreasing drivers’ speed and improving their visual scanning (Schepers, 2011).

This study primarily considered crossing conflicts at intersections, not turning conflicts. Even so, some designs, such as two-way cycle tracks and colored pavement, were found to increase, rather than decrease, collisions. Merging before the turn was not included as an option.

— 6 —

Perceived danger from motor vehicles is real, and protected bike lanes help alleviate that fear

The chief obstacle to bicycling, especially for women, children and seniors is perceived danger of vehicular traffic. This perceived danger from cars appears to be real, and there is a preference for cycle tracks over roads in face of that fear. (Winters, Teschke, 2010) I can’t dispute that many bicyclists fear being hit from behind, even though that’s objectively less likely than other conflicts. This attitude, however, is only strengthened by the implication that painted bike lane stripes are inherently unsafe. Still, this is primarily a mobility issue, discouraging bicyclists from using certain facilities.

The greater concern is that these bicyclists often fail to recognize the danger of crossing and turning conflicts (hence the ineradicable popularity of sidewalk riding), and that is a safety issue. Separated facilities reinforce this pattern, too, by explicitly promising bicyclists that infrastructure can protect them from traffic. These facilities promote a comforting reassurance that, while understandably appealing, may not always be justified.

Of course facilities should be attractive and comfortable to their users, but those qualities should not be founded on unreliable premises.

Studies of early US protected bike lanes demonstrate safe operations, and widespread appeal

A landmark study in 2014 included direct observation, counts and preferences surveys to understand the effectiveness of protected bike lanes at encouraging safe and comfortable bicycle mobility (NITC, 2014). Key finding includes:

• Separated bike lanes were observed to be safe: Out of 6100 observations, there were zero (0) “Major” or “Substantial” conflicts. There were (5) “Minor” conflicts with precautionary breaking and 306 “Precautionary” observations with “Low risk” and minor change of direction.
• Ridership within the studied facilities increased 11% over the before conditions • Public support for these facilities was strong, among all groups of surveyed people.

The appeal of these facilities isn’t surprising, as discussed just above. The NITC study is a good one, by far the most thorough in this group; I thought so when it was published, and I haven’t changed my mind. But I draw rather different conclusions from it.

Note particularly that the intersections in this study resolved turning conflicts not through the typical right- hook geometry, but by different means:
“Three different design approaches were evaluated. First, some designs require the bicycles and turning vehicles to ‘mix’ in the same space. These designs are called ‘mixing zones.’ The second approach moves the through bicycle from the protected lane near the curb to the left or right of the turning traffic into a narrow through bike lane. These are called ‘turning zones.’ There is a defined turn/merge gap for this maneuver and the lanes are marked with dotted lines recognizing that larger vehicles may encroach on the bike lane due to the narrow widths of the turning lanes. The third design involves signalization to separate the bicycle and turning — 7 —

vehicle movements.”
These design elements closely resemble those of conventional painted bike lanes and vehicular traffic engineering, so I’m reassured that they were found to be safe and effective. But equally important:
“With some exceptions . . ., the large majority of drivers and bicyclists stated that they understood the intent of the mixing zone designs and were observed to use them as intended. In addition, a majority of bicyclists using the intersections stated feeling safe.”
In other words, both drivers and bicyclists understood, accepted, and approved the intersection designs included in this study. That is a high bar to clear, and it suggests that even where there might be valid reasons for physical separation between intersections, a broader range of design features should be considered in the vicinity of intersections themselves.

Research into conflict mitigation is ongoing
Research continues, with ongoing attention to conflict mitigation. These tools include signalization at high turn volumes, reduced radii, increased separation, minimizing exposure, and visual enhancements (MioTraffic, 2022).

There seems to be a typo in this citation, and the PDF file that Nick provided must have been damaged somehow and cannot be opened. The corrected reference is MicroTraffic, “Advancing North American Design Practices to Mitigate Bicycle Right-Hook Conflicts”; a copy can be found here.

I find this report, which deals primarily with separated bikeways and sidepaths, refreshingly forthright in several respects. Its very title acknowledges that the geometry of unmerged separate facilities can present an inherent car-bike crash hazard. It also observes that:
“Despite painted bike lanes often requiring that drivers merge with cyclists to make a right turn from the bike lane (dashed line on approach), many do not. This observed behaviour suggests that the typical painted bike lane merge is not working as intended, resulting in the same potential right-hook conflicts as with a protected approach but with driver and cyclist behaviour being less predictable to one another. For improved cyclist comfort and a more inclusive design, designers are likely better off simply designing for full physical separation up to the intersection, taking the many considerations raised in this study into account.” This, like the NITC study, is highly unusual in recognizing that there are methods of routing vehicles and bicycles through intersections without creating a right-hook geometry. Unfortunately, it immediately goes on to discard that approach, and to conclude that we might as well cement the right-hook conflict into our facilities and deal with it as best we can. This is at least a straightforward rationale for preferring separation (even if not one I would accept), which is a great deal more than proponents are usually able to offer.

Still, I would have preferred to ask, What is the evidence that drivers fail to merge? (The NITC study found otherwise.) Is there a correlation between the rate of driver compliance and intersection conflicts? Could driver behavior be improved by signage, markings, or other means? Why abandon these ideas, when so many other options were chosen to pursue? The NITC study’s findings suggest that merging and related designs deserve thorough consideration.

It’s also important to recognize that taking physical separation as the default renders it impossible for those — 8 —

drivers and bicyclists who want to merge or change lanes to do so. Furthermore, even if we assume, for the sake of argument, that there are effective mitigations for intersection conflicts along physically separated bikeways, those mitigations can be provided, for the most part, at only a limited number of discrete locations along the bikeway. At all other intersections and driveways, motorists and bicyclists will be left to their own devices.

More generally, these facilities train bicyclists to pass right-turning motorists on their right, and motorists to turn sharply across the path of overtaking bicyclists, at all locations, even where no physical barrier prevents merging. The potential increase in bike-car collisions that such behavior might produce on shared roadways or those with conventional bike lanes would not be captured by isolated studies of separated bikeways.

Recent updates to the AASHTO Guide for the Development of Bicycle Facilities (2024) include comprehensive design guidance for the design of protected bike lanes.

I’ve already discussed the bias in this guide in my August comments, which there is no need to repeat here.

Conclusion

Recommendations in the update to the Palo Alto Bicycle and Pedestrian Transportation Plan for protected bike lanes in higher traffic contexts is appropriate and in line with national guidelines for facility selection.

The overall safety and comfort performance of an individual bicycle facility is highly influenced by design details beyond the basic facility type selection. We encourage the City of Palo Alto to pay special attention to the design engineering phase of all protected bike lanes to implement the latest practices in design to increase conspicuity and visibility of bicyclists, decrease driver speed at turns and conflict points, and increase yielding rates at turns.

Physically separated bikeways may have a place in individual situations where their drawbacks (of which intersection conflicts are the most serious, but not the only ones) can be addressed. I urge the City to consider recommendations for them in the BPTP Update with great caution; these are expensive installations that may provide little benefit, or even its opposite, and are not easily reversed. The evidence in their favor, as I mean to demonstrate here, even if it’s crept into recent design and facility selection guidance, is much less robust than their proponents are ready to acknowledge.

I agree, however, with Nick’s second paragraph, except that I would replace “protected bike lanes” with the more general “bikeways.”

From: Pamela Mayerfeld
To: Council, City
Subject: Changing E Meadow Dr between Middlefield and Fabian into a separated bikeway would create dangerous situations
Date: Monday, December 1, 2025 7:45:43 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Please do not change E Meadow Dr between Middlefield & Fabian by creating a separated bikeway. E Meadow Dr in this area is presently wide enough to enable both bikes & cars to use it safely. A separation is not necessary and will make both E Meadow Dr & Ross Road more dangerous for bicycles and pedestrians
Converting E Meadow Dr to a separated bikeway would require the elimination of necessary parking resulting in reduced safety for the following reasons:

Ramos Park is actively used by people from around the area for soccer practices & games, volleyball games, picnics, parties, etc. They need a place to park as they often bring equipment and there is no parking lot there.

Taking parking away from E Meadow Dr would force people to park on Ross Road which is a shared bike boulevard. Ross Road would be more dangerous to bike on as it doesn't have as much room for moving cars, parked cars & bikes
Parking on the south side of E Meadow is already often full so people park on the north side of E Meadow as well as Ross Road -- this would increase.

It's more dangerous for pedestrians to cross from the north side than to walk directly into Ramos from the south side of E Meadow.

Ramos Park's wonderful new bathrooms are used often by many people including PA city workers -- where would they park to do so?
People make U-turns on E Meadow Dr when parking adjacent to Ramos Park is taken, this would increase significantly, making E Meadow Dr more dangerous overall.

There are multiple ADUs on E Meadow Dr (and inevitably more coming) so cars don't have garages or driveways and need to park on the street
Please listen to the local people who live in/near E Meadow Dr & use Ramos Park. Making E Meadow Dr a separated bikeway would change a safe transit route into a dangerous transit route.

Thank you
Pam Mayerfeld
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From: Kyla Farrell
To: Council, City
Subject: Reguarding the Bicycle & Pedestrian Transportation Plan Update Date: Sunday, November 30, 2025 9:31:28 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear City Council Members,
I am a resident of Midtown Palo Alto with two children in PAUSD. I am writing you regarding the proposed Bicycle & Pedestrian Transportation Plan Update.

I implore you to prioritize making the Middlefield business districts a "bicycle friendly zone" like the city's other business districts.

South Palo Alto residents shouldn’t have to bike all the way to Downtown or Cal Ave just to run an errand or grab a coffee. We have grocery stores, restaurants, pharmacies, youth programs, and community hubs right here in Midtown—but they’re not safely reachable by bike.

Additionally, nearly half of PAUSD’s K–8 students—around 3000 kids—live or attend school south of Oregon Expressway and east of Alma. These children and their families frequently travel to Mitchell Park and multiple shopping centers in the Midtown area.

Middlefield Road today is the opposite of what a neighborhood street should be: cars regularly travel 35–40 mph in a 25 zone, bike lanes vanish without warning, sidewalks are cramped, and bike parking is almost impossible to find. These conditions make the corridor hostile for anyone who isn’t in a vehicle.

The core problem is that in South Palo Alto Middlefield has been allowed to function as a fast- moving cut-through rather than as a neighborhood street. This is not the case on the north side of Oregon, where Middlefield drops to two lanes with clear bike lanes and traffic slows. Why do we need four lanes on Middlefield in South Palo Alto but not North Palo Alto? Middlefield should be reduced to two lanes through South Palo Alto—especially from Loma Verde to Oregon where the traffic lanes barely accommodate a modern car and there is zero space for bikes, but many local businesses which would be easily accessible by bike or on foot. The fact that Middlefield works with two lanes of traffic north of Oregon is only proof that we could drop to two lanes in South Palo Alto as well. Imagine how lovely the Midtown commercial strip could be with additional street trees and a protected bike path. We could have art fairs and farmers markets where we live, not just on Cal Ave or Downtown. And then the corridor can begin to function like other Palo Alto business districts where safe, reliable biking is the norm.

Additionally, I ask that you prioritize:

Further improvements around Alma/Churchill to help keep our Paly students safe since grade separation is still a long way off.

Prioritize the bicycle improvements planned on E. Meadow despite ongoing budget constraints (budget constraints have already delayed this critical safety improvement project impacting our Gunn, JLS and Fairmeadow students).

Approval of the proposed El Dorado underpass but with the underpass taking cyclists and pedestrians under Alma as well as under the railroad tracks (the current proposal would install a traffic signal and require bicyclists and pedestrians to cross Alma).

Prioritizing bike lanes early in the San Antonio Road Area Plan.

Best,
Kyla Farrell
From: [email protected]
To: Council, City
Subject: Comments on the Draft BPTP
Date: Saturday, November 29, 2025 4:53:50 PM
Attachments: Draft BPTP Comments PDF.pdf
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Honorable City Council,

Here (attached pdf) are my comments on the DRAFT BPTP you will study on Monday night.

Thank you for considering my comments.

Penny Ellson
(writing as an individual citizen)
Virus-free.www.avg.com
Updated Draft BPTP Comments, 11/14/2025 – Penny Ellson
Thank you. I appreciate the time staff and others have spent listening to the public and writing this. I appreciate the expertise applied, and I look forward to supporting efforts to realize this vision.

Comments and questions follow. –Penny
Comments:
p.53- Linear Barriers map needs correction. Creek barriers do not interrupt all the bike routes that the barrier map indicates. For example, Matadero Creek has bridge crossings for bikes/peds/autos on Greer, Louis, and Ross. (Perhaps these were left out intentionally for some reason?) Also, the bike/ped Magical Bridge over Adobe Creek in Mitchell Park is missing from this map. These are just a few examples I noticed where the map shows barriers on bike/ped routes where facilities to cross the barrier already exist. There may be more. I mentioned at least some of these in previous review phases. I did not carefully check the entire map.

Existing Bicycle Facilities Map excludes important facilities. Please re-check this map. A few omissions I noticed are:
• Paradise Way connection to Bol Park path (used as a school route). • Georgia-Coulombe-Donald school route connection to Bol Park path at Gunn HS • Nelson Drive connection to Charleston Road. This is an existing well-used school route (crossing guard location at Charleston/Nelson) and connection to Cubberley and probable future bike connection to SARAP area. Nelson Drive is part of the adopted City of Palo Alto School Commute Corridors Network. (See 2012 BPTP , pp. 6-22,7-1,F-8 and Comprehensive Plan Program T6.4.1 Consider the Adopted School Commute Corridors Network and adopted “Walk and Roll” maps when reviewing development applications and making land use and transportation planning decisions. Incorporate these requirements into City code when feasible. • Mayview is a well-used school route that is not shown on this map. There is a Crossing Guard post at Mayview/Middlefield.

Again, I did not thoroughly check the entire map.
p.89—Upzoned housing sites in the SARAP area are mostly well outside the ¼- ½-mile urban walkability radius of the San Antonio Caltrain Station. Yet, this area is identified as a pedestrian district and not a future bicycle-friendly district. Bikes will be essential to get people out of cars here because of distance from the train station and because auto parking requirements for these high- density buildings are low. There are no safe, comfortable pedestrian crossings and minimal bus transit.

There are almost no bike facilities at all on this auto-dominated, high volume, fast, truck route arterial.

This area has been upzoned for transit-oriented density. It must be turned into pedestrian- and bicycle-friendly district, or essential mode shift will not be possible.

Midtown should also be a bike-friendly district. I bike and walk there a lot to shop. Kids bike there after school. People bike there to shop. It already is a pedestrian-friendly district. It needs to be more bike- friendly. Lots more easy-to-find bike parking is needed. (More racks and wayfinding signage so newbies can find it and drivers notice it!)
Downtown is already a very bike/ped-friendly environment compared to most other parts of town.

Downtown is already much more transit-rich, bike friendly and ped-friendly than upzoned areas of south PA .Prioritize parts of town that are being impacted by growth and have almost no bike facilities at all. No grid network of streets, no existing grade separations… SARAP area, in particular, is a bike facility desert. Fixing the total lack of any useful bike facilities in the SARAP area before new residents move in must be a high priority. Resources are limited. Please prioritize bike/ped improvements to massively upzoned areas that are completely unprepared for the growth that is coming. Move faster. Build bike/ped facilities before new residents move in, so new housing draws buyers and renters who want alternatives to driving. To do this, great bike/ped facilities must be in place when they move in to support healthy, active, sustainable alternatives to driving.

Commute habits get established quickly. Let’s set these new Palo Alto neighborhoods up for success. p. 96- Policies—I see no mention of continuing city collaboration on specific popular community bike route exploration events like Bike Palo Alto! Please correct this omission. p.100—Potential changes to PABAC Structure
Before we decide how to change the committee, let’s please consider why we are doing this. What are we trying to accomplish with this change? That goal is not clear to me from the list of potential changes I see here.

A smaller PABAC with term limits makes sense for efficient discussion and decision-making. However, given the time it takes to acquire depth of knowledge to be useful on this committee, it would be good to keep people on longer—for instance, a maximum of three 3-year terms. They can reapply after a three-year hiatus. This means that hard-working, knowledgeable committee members with historical knowledge won’t be lost because of term limits. (Term limits have well-known disadvantages. Less experienced committee members can be weak advisors, especially in an area that requires some technical knowledge, familiarity with policy and local history, and a lot of local bicycling/walking experience.) How are other similar communities’ BPACs organized? Another important question is what should be the role of this new PABAC in relation to PTC, CC, and staff? PTC agenda time appears to be filled increasingly by development projects and busy work, not bike/ped projects. Ditto for PABAC. Transportation projects don’t rise to the top of PTC agendas as often as they should. How might PABAC work with staff, PTC and CC more effectively? I agree that a smaller committee would work more efficiently. However, all members must be people who usually walk, bike, use mobility devices other than cars for their primary modes of transport. It’s more important that PABAC members are people who regularly bike and walk for transportation and recreation. Without that experience and perspective of the street system, they cannot be useful on the committee. I’d like to see at least one representative who uses these facilities with a supportive mobility device like a wheelchair or someone who may have other differences that our city’s transportation system isn’t adequately supporting (sight or hearing impairment, etc).

Something staff might think about: Staff often does not tell PABAC what kind of feedback they are seeking. For instance, for the last four months, there has not been an Action Item on any PABAC agenda.

If staff wants a vote taken, they could offer an Action Item. There have been lots of Discussion Items, but limited guidance from staff about what kinds of specific feedback they seek or what questions they’d like answered. I notice that when this sort of guidance is provided on CC and PTC agendas, and it helps to focus discussion and voting. I think something similar could be helpful to PABAC (and, ultimately, to staff to get the information they seek).
p. 105 (107)—San Antonio Road Separated Bikeway. Will this be on the WB or EB side of the road or both? If it is only on the WB side of the road, this likely will force bicyclists to go out-of-direction to get to the train station from new homes on the south side of San Antonio (where most of the high density housing is to be built). Out-of-direction travel is a known deterrent to bicycling. Given what Mountain View has recently announced they are building at Rengstorff/Leghorn (901-987 N. Rengstorff: 15-stories, 455 units), this intersection is likely to be very impacted by new traffic. Also, if there’s no direct facility on the southside, bicyclists may be incentivized to ride wrong-way on the sidewalk—a hazard for pedestrians on the sidewalk and a safety hazard for bicyclists at intersections like Middlefield/San Antonio Road. How do we prevent that? This is why I have been pressing the ROW issue so hard. I think a two-way facility on the south side of San Antonio is extremely important for safety and for successful, essential mode shift in this new high-density area. p.112
Appendix E- Only downtown, the area of town with the best existing bike parking infrastructure (excepting, of course, PAUSD school sites) got a Bicycle Parking Survey? We need parking surveys of areas where there is known existing paucity of easy-to-locate-and-access bike parking and a lot of development coming. Look southeast and southwest where thousands of units of new housing and other high-density development are going—and existing facilities are lacking.

Appendix F, p. 4- The first housing proposal sites are on San Antonio Road, where few people currently live. As a result, relatively low activity level is reported there—even though future residents will surely need to shop, go to work, use the Caltrain Station. There is a gaping “demand hole” in what surely will be a busy activity area along all road sin the SARAP area and near the San Antonio Caltrain Station. Could estimated future demand be incorporated in this map somehow? As it stands, this map is very misleading about what is coming. When will cumulative traffic impacts analysis of MV and PA development in/near the SARAP area be complete? I’m disappointed this work wasn’t done before the rezoning and housing element changes were complete.

Investment in bike/ped infra in SARAP areas before new residents move in will be essential to achieve mode shift. Mode choice habits form quickly and are hard to change once established. Further, people who are inclined to bike are more likely to buy homes where they see good bike infra. Likewise, people who prefer to drive are more likely to buy where they see lots of on-street parking. Do not delay. Let’s get this done, or fully developed San Antonio will be a serious auto congestion problem.

Appendix F, p. 12- Replica only captures data from people who carry phones. Lower income people who cannot afford a cell phone may be more inclined to bike or walk to a bus stop or train station. Also, many people who like quiet time, like me, do not take smart phones everywhere when they walk and bike. Many parents do not give smart phones to their kids.

There are so many pages of disclosures on what does and doesn’t work in this data, I hope some traffic counts were done to ground truth the Replica counts. For instance, based on previous multi-modal traffic counts on Nelson Drive and my daily personal experience there, the Replica report is inaccurate— very low.

Appendix F, p. 14 says, “K-12 student personas are constructed synthetically, with the only daily activity being a trip to school.” What about students walking or biking to/from after-school activities or jobs in Palo Alto? We plan bike/ped routes for after-school commutes to community centers, libraries, and playing fields and courts for practice, etc. because we know kids with working parents generally have organized after-school activities.

One daily school trip is an incorrect assumption. (Each school commuter generates two trips daily, not one. One trip to school and one trip home.) Please look at actual campus bike counts and multiply by two to check your Replica data against those numbers. Ditto for every PAUSD school.

Appendix F. Fig. 7, p.18- That there no bike trips recorded on this Replica data-informed origin/destination map for Paly or Gunn HS or Greene MS or Fletcher MS. This is a very big red flag.

The city has recorded bike count data for these campuses. The Replica data map does not at all conform with what we know about bike trips to these campuses. I pointed this out when PABAC discussed it.

What actual counts were done to ground-truth this data? Appendix F. Fig. 14, p. 24 - Same comment (I said this at PABAC). Please note there are no walking trips recorded to any PAUSD elementary, middle, or high school. This data conflicts with school commute data the city has been documenting for decades.

This looks like adult bike commuter phone data. These trips mostly look like adults dropping off kids at childcare and going to work. I’d bet most of them work at SRP or Stanford University where there are incentives for tracking trips. I pointed this out when PABAC reviewed it. Was this checked? Appendix F, Table 3, p.30 – High-density housing (built or proposed to be built should be on this list.

Appendix F, Figure 18 p. 32 –The San Antonio Caltrain Station and SARAP area likely show only medium to low demand because proposed high-density housing hasn’t been built there yet. How will staff account for upzoned and proposed future high-density development in this demand scoring, if at all? Appendix G. Fig. 3, p. 9 - See my remark at the top of this document re: the Linear Barriers map.

Appendix G. Fig. 9, p. 15 – It looks like a new South Palo Alto Connectivity option at Colorado that I’d not seen before has been added. Why was this option not in the original set (and, at this writing, is not on the South PA Connectivity project page)? Is this an error? Appendix G. Fig. 9, p. 15 – Re: Option H. I have asked what the grade change and uphill climb length of the San Antonio overpass bike facility would be. I still don’t see this information in project documents, and it seems like important information for decision-making. Is this option still on the table? This project would cross into MV jurisdiction has City of Mountain View weighed in on this? Appendix G. p.-16 – The summary of Transit Barriers analysis for San Antonio Caltrain Station fails to mention that there are zero existing bicycle facilities in the upzoned housing areas that would safely connect bicyclists to the existing train station bike/ped facilities. Most of the SARAP parcels that have been upzoned for housing are outside the ¼-1/2- mile urban walkability radius, so excellent bike facilities to the station will be essential. Also, the existing pathways into the station are too tight for high volumes of pedestrians and bicyclists to share safely without dismounting. The Alma pedestrian crossings (at Mayfield and at San Antonio Avenue) are both impacted by very fast, high volume auto traffic which will increase with increased area population. Though there are traffic signals at both crossings, sometimes drivers do not stop. Connections to this train station from future housing need a lot of work to prepare for transit-oriented density that is coming to this area. (See Bicycle Level of Stress maps in Appendix H.) SanAntonio Caltrain Sation offers a connection to Shower Drive and California Street and San Antonio Train Station. It would take cross-jurisdictional cooperation to develop this, but both cities are developing big projects in this area. They both (along with Caltrain) have an interest in increasing train boardings here and providing better bike/ped access to the shopping center.

Appendix H. Fig. 3, p. 4 – I agree with a lot of this map, except for San Antonio Road intersections at Charleston, Middlefield and Alma where there are zero or severely inadequate bike facilities. At San Antonio/Middlefield, for instance, there are no bike facilities at all on three of the approaches and a narrow, Class II painted bike lane on SB Middlefield only on the south side of the intersection. The entire intersection and all of its approaches should all be marked bright red. There are similar problems at the other above-mentioned intersections. I said this in my earlier response to this document. Google Earth and on-the-ground experiences of these locations are very different.

Appendix H, Fig. 9, p.21 and Fig. 10, P . 22– I invite staff and City Council and PTC to please take a bike ride with me at commute time to the San Antonio/Middlefield intersection. Please attempt to execute a left turn from SB Middlefield (which future residents of this area will have to do to get home). As you do this, watch out for truck beds that swing wide. Middlefield, at this intersection and on its approaches, is not LTS 3 or LTS 1. It is LTS 4, especially at commute times—when it matters most.

Appendix K, p. 4-Charleston is listed as a HIN. I’m curious whether anyone checked the dates of the KSIs against completion dates of various phases of the Charleston-Arastradero Plan. I know that the one fatality between Carlson and Nelson on Charleston occurred May 5, 2018 before that segment of the project was built. Existing buffered bike lanes, narrower travel lanes, built median refuge islands and new signals did not exist at that time. Please check when these KSI’s occurred and the completion dates of each project segment to understand whether today’s existing conditions need improvement. Here are road diet completion dates for each phase:

Phase 2: Charleston Road (from Alma Street to Middlefield Road, not including the intersection of Middlefield):
 Start of construction (date the Notice to Proceed was issued to the contractor): June 8, 2018  Construction completed (date the City accepted the project): November 12, 2020

Phase 3: Charleston Road (from Middlefield Road to San Antonio, Alma Street to ECR) and Arastradero Road (from ECR to Los Palos Avenue):
 Start of construction (date the Notice to Proceed was issued to the contractor): August 23, 2021  Construction completed (date the City accepted the project): July 1, 2025

Appendix L, P. 22- Advisory Bike Lanes--We need an accompanying education program to teach people (especially drivers) how to navigate these, or we’ll have another uproar similar to the traffic circle outcry. U.S.-trained drivers will not know what to do. They must be taught. How can we reach adult drivers to teach them?

Appendix L, p. 24- BLVD_18 – Has staff considered the likelihood that drivers from San Antonio Rd. and San Antonio Avenue will start exploring these BB routes with the help of navigation apps like Waze as auto cut-throughs to Charleston to bypass arterial congestion. Would some filtering make sense?

Appendix N- Does this list represent a complete list of present and proposed BPTP policies and programs that will be proposed? Are these policies and programs to be added to existing policies and programs or are they intended to replace any existing policies and programs? Were any policies or programs removed? If so, which ones? It is difficult to comment without knowing that.

Appendix N, p.5 – PABAC Structure- This reorg proposal doesn’t speak to a specific goal. 1). Please be more clear about what you are trying to accomplish by making structural change. I’m not opposed. What problems we want to solve with this reorg? What is the Goal? 2). This suggests PABAC include new people from:
• non-profits (Which ones? Why?),
• advocacy groups (a number of current PABAC members are SVBC members, including a local team co-Chair, other groups?),
• What about people with disabilities?
• More women who bike.
• People from diverse backgrounds—(I don’t remember PABAC ever turning anyone away who expressed interest in joining)
• TMA (PATMA makes sense, but isn’t Cedric on PATMA’s board?) • City committees (which committees—toward what purpose? Are other committees asking for a seat?
• Other groups (What groups? Why?)
This kind of diversity is less important than how much experience PABAC Members have walking and bicycling and how broadly afield they bike. The most important thing about this committee is that its members actively walk and bike regularly in Palo Alto. It is evident that some city staff and most consultants do not, especially in south Palo Alto.

PABAC Members should be familiar with local routes as bicyclists and pedestrians, and be willing to read policy documents and spend time reviewing and understanding and commenting thoughtfully as interested laymen on data, policies, programs and plans.

I shared what I thought about committee size, purpose, and term limits in another section above.

Here is how our web page defines our role:
“Palo Alto receives technical advice from its volunteer Pedestrian and Bicycle Advisory Committee (PABAC). PABAC is a citizen advisory committee which reports to the Chief Transportation Official. Members have interest in or knowledge of bicycling. The Committee's role is to review all issues related to bicycling in the areas of engineering, enforcement, education and encouragement.” (Note there’s no mention of pedestrian issues here. Huh.)
We might start this reorg process by rewriting this statement. We should agree on PABAC’s purpose, how we fit in the city’s organization, and define the kinds of tasks that need to be accomplished by the committee, and also staff’s role in that. Once we’ve defined that, framing the rest should be easier.

Appendix N- Missing Policy Change Recommended by PABAC unanimous vote at our May 7, 2024 meeting. PABAC recommended adding the following sentence to Comprehensive Plan T4.1: “Street closures may be considered when such closure will enhance safety or will increase use of active transportation modes”. Was this omission a mistake, or did staff decide not to include it? Please let PABAC know. Thank you.

Appendix N: To Older Adult Mobility Program, I would add encouragement and education programming to help people find ways to stay active longer through walking and bicycling as our population ages.(See Mineta Institute Study on this.) I think the Trishaw idea is unlikely to have legs.

Appendix N: Electric bicycle engagement. I was expecting more substantive work on this. We need parent education on what to buy and not buy for kids --for starters. We need to work with the State on age and licensing requirements to ride some of these vehicles. We have kids rolling around at high speeds on two-wheeled vehicles are not appropriate for their developmental ability to handle them.

Many of these vehicles are not street legal. We need a well-considered education program for students and parents.

Appendix N: Under Bike Parking Requirements—Add, “Do an inventory for all parts of the city where none has been done.” We cannot fix problems that are invisible because we haven’t looked. Also, use the bike parking survey to identify where we need to add wayfinding to bike parking wherever it is needed citywide.

Appendix N: Under Walk & bike-Friendly Environment. I’m not sure LEED-ND requires bike facilities (Does it? I think it does reward them). Let’s choose our city’s requirements for bike and ped facilities that represent the best practices.

Appendix N: As the city rolls out new kind of bike facilities, like protected intersections, bike boxes, cycle tracks, protected bike lanes, advisory bike lanes, we need an education program for DRIVERS as well as bicyclists on how they should be used. Maybe this is something we work on with PA Weekly? DMV? SVBC? Stanford? All of the above?
Appendix N: regarding PABAC Structure. See my comments above. It is disappointing this was not included until the last minute, allowing no time for discussion with PABAC Members. This Description needs thorough discussion and revision.

Additional Request that I’ve been meaning to raise:

Please consider restoring 1998 Comp Plan Policy T-36 –specifically for areas where high volumes of auto drop-offs occur at locations where children might be walking or biking, such as school sites, playing fields, community centers, etc. : “Make new and replacement curbs vertical where desired by residents. “ Vertical curbs prevent drivers from parking on sidewalks, a common and undesirable practice in area where rolled curbs are not separated from sidewalks by planting strips. When conversion from rolled to vertical curbs is undertaken, the minimum area should be, in general, a street block and not individual properties. “
I’ve observed, and I know staff has too, some awful driver behavior in these locations. Vertical curbs would provide some physical safety control of the sidewalk space in these sensitive locations. Thank you, in advance, for considering this idea.

One final comment:

Park BB—2012 BPTP plan is much better. That’s all I have to say about it. Southern part of the Park BB is what needs work.

From: Lara Anthony
To: Council, City
Subject: Bicycle & Pedestrian Plan Update
Date: Friday, November 28, 2025 3:16:27 PM
Attachments: Lara Anthony Council Letter BPTP- 112825.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Dear Honorable Council Members,
Please find attached a letter regarding the Bicycle & Pedestrian Transportation Plan Update.

In short, please add to the Plan further safety improvements around Alma/Churchill, and improved bicycle access to Middlefield businesses for the many South Palo Alto residents and students who frequent them (but cannot currently do so safely or comfortably on bicycle).

Please also prioritize the South Palo Alto Bikeways project (safety improvements to E.

Meadow) despite ongoing budget constraints, and please approve the El Dorado underpass, but with the underpass also
taking the cyclists and pedestrians under Alma, not just the railroad tracks.

Thank you for your service and for advancing enhanced bicycle and pedestrian safety projects which greatly benefit our students, families, and our whole community.

Best regards,
Lara Anthony
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Dear Honorable Council Members, My name is Lara Anthony, I’m a Palo Alto resident, PAUSD parent of two elementary school

children

(as

well

as

host

parent

of

an

exchange

student

attending

Paly

this

year),

and

I

am

the

Palo

Alto

PTA

Council

Chair

for

Safe

Routes

to

School,

however

I

am

writing

today

as

an

individual.

I commend and thank the City for advancing improved safety and connectivity for bicyclists

and

pedestrians

as

outlined

in

the

draft

Bicycle

&

Pedestrian

Transportation

Plan

Update

(the

“Plan”);

however,

while

there

are

numerous

important

and

worthwhile

projects

enumerated

in

the

Plan,

there

are

two

glaring

holes

where

critical

projects

are

missing

from

the

Plan.

First, the Plan should prioritize on a near-term basis any and all additional engineering and

infrastructure

opportunities

possible

to

make

it

safer

for

students

on

bicycles

to

get

to

and

from

Palo

Alto

High

School’s

Churchill

entrance.

The

recent

improvements

around

Alma/Churchill

help,

but

grade

separation

is

still

a

long

way

away

and

further

safety

improvements

are

needed

on

Churchill

Avenue

between

Emerson

and

Castilleja

to

protect

our

students

in

the

meantime.

Please

consider

with

urgency:
● A stop sign on Churchill at Castilleja for eastbound traffic (understanding train regulations

prohibit

a

stop

for

westbound

traffic);
● No Right Turn on Red restrictions for westbound Churchill traffic at Alma and southbound

Alma

traffic

at

Churchill

(at

least

at

school

start/end

times)

-

there

is

already

a

“no

right

turn”

light

up

arrow

there

that

can

be

used;

and
● Green striping and signage to help Paly students cross to the correct side of the street on

eastbound

Churchill

between

Alma

and

Emerson

when

leaving

the

school.

Second, the Midtown business district on Middlefield from San Antonio through Greene Middle

School

should

be

a

bicycle-friendly

zone

like

the

City’s

other

business

districts.

For

residents

in

south

Palo

Alto,

it

usually

doesn’t

make

sense

to

bike

all

the

way

to

the

bicycle-friendly

zones

downtown

or

around

Cal

Ave

for

our

everyday

shopping,

errands,

activities

or

a

quick

coffee

or

bite

to

eat;

however,

the

businesses

and

community

centers

in

south

Palo

Alto

cannot

be

safely

or

comfortably

accessed

by

bicycle.

For

example,

my

children

enjoy

ice

skating

classes

at

Winterlodge

Ice

Rink,

baseball

at

Middlefield

Ballpark,

and

ice

cream

from

Rick’s

or

Baskin

Robbins,

and

I

frequent

many

Middlefield-based

businesses

regularly.

Despite

that

we

prefer

to

bike

and

live

only

a

few

minutes

away,

we

typically

drive

to

our

Middlefield

destinations

because

it

doesn’t

feel

safe

or

comfortable

to

bike

to

them.

This

corridor

also

contains

five

public

schools

and

several

private

ones,

Mitchell

Park,

Library,

and

Community

Center,

several

shopping

centers,

Allcove,

groceries,

pharmacies,

restaurants,

coffeeshops

and

numerous

other

small

businesses,

dance

and

martial

arts

schools,

and

other

activity

providers.

As I’m sure you are aware, vehicle speeds on Middlefield frequently exceed 35-40 mph despite

the

posted

25 mph

speed

limit;

where

bicycle

lanes

exist,

they

disappear

without

warning; the sidewalks are narrow and used by pedestrians; and there’s virtually no bike parking.

It

is

the

opposite

of

bicycle

friendly.

I

urge

you

to

reconsider

the

Middlefield

business

corridor

in

south

Palo

Alto

for

real

bicycle

enhancements

to

allow

local

residents

and

the

many

JLS

and

Greene

Middle

School

students

who

frequent

Middlefield

destinations

to

do

so

safely

and

comfortably

on

bicycle.

Additionally, I am grateful to see upgraded bike lanes on East Meadow included in the Plan.

That

project

(South

Palo

Alto

Bikeways)

was

previously

intended

to

begin

construction

around

now

but

was

delayed

last

year

for

budget

reasons.

Understanding

we

continue

to

be

budget

constrained,

I

urge

the

City

to

prioritize

this

critical

school

route

(serving

students

and

families

at

JLS,

Fairmeadow,

Gunn,

and

private

schools,

as

well

as

Mitchell

Park

destinations)

and

ensure

that

budget

constraints

don’t

cause

any

further

delay

to

this

very

important

project.

The San Antonio Road Area Plan is detailed in a separate project. Please prioritize excellent

bicycle/pedestrian

facilities

development

early

to

support

transit-oriented

density

that

is

being

planned

in

this

area.

Please

ensure

that

these

facilities

are

completed

and

ready

to

use

before

occupancy

permits

for

new

housing

are

issued.

Finally, I strongly support the PTC and staff’s recommendation that the City proceed with plans

for

a

tunnel

at

El

Dorado

Avenue.

However,

the

tunnel

needs

to

take

bicyclists

and

pedestrians

under

Alma

as

well

as

the

railroad

tracks.

Alma

operates

like

an

expressway

in

this

part

of

Palo

Alto,

where

vehicle

speeds

are

typically

over

40 mph

and

the

proposed

signalized

multi-lane

intersection

configuration

presents

sightline

problems.

If

the

signal

changes

while

someone

is

in

the

intersection,

sight

lines

of

shorter

young

people

on

bikes

and

on

foot

will

be

obstructed

by

stopped

or

passing

vehicles

in

the

multiple

lanes.

(This

is

very

different

from

the

Homer/Alma

intersection,

which

is

slowed

due

to

several

blocks

of

downtown

cross

traffic,

merges

and

signals

and

a

25 mph

posted

limit).

For

students

and

families

to

be

safe

and

comfortable

using

the

planned

underpass,

the

design

needs

to

grade

separate

Alma.

A

signalized

intersection

would

be

insufficient

at

this

location

for

nearly

all

users.

Thank you for your service and for making our community a better, safer place for children,

families

and

all

residents.

Best regards, Lara Anthony

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