August 2024: Feedback on Revisions to Policy M-9 Transportation Demand Management and Related PIP

In response to: https://go.boarddocs.com/vsba/arlington/Board.nsf/files/D7NME55AC573/$file/M-9%20Transportation%20Demand%20Management.pdf

To: "Zecher Sutton, Bethany" <bethany.zechersutton@apsva.us>, "Priddy, David (Arlington County Public Schools)" <david.priddy@apsva.us>, "Marku, Steven" <steven.marku@apsva.us>

Board members Zecher Sutton & Priddy and Mr. Marku;

Thank you for the opportunity to comment on the review of APS Policy M-9 Transportation Demand Management. This policy gives the School Board the opportunity to set clear direction for transportation to and around Arlington’s public schools. 

Transportation is critical to the functioning of schools and the use of school buildings. At the same time, certain transportation, particularly by motor vehicles, can injure or even kill students, staff and visitors. Transportation, particularly by non-electric motor vehicles, is also a significant contributor to poor air quality, by which children are particularly impacted, and climate change, which our children will have to live with in the future.  Poor transportation demand management costs APS needed funds - such as when APS must build and maintain large parking lots or when teachers and staff are forced to manage private car pick-up and drop off lines.

The revision of this policy gives the School Board the opportunity to make a clear statement on how transportation should be managed at schools. Unfortunately, the revised policy and PIP included in the July 26, 2024 memo from the Policy Review team misses the opportunity to make APS’s priorities clear.

In particular, in the Transportation Demand Management policy, the School Board should clearly state goals, including that APS should:

1. Adopt Vision Zero strategy to school transportation as a comprehensive and holistic approach to eliminating traffic fatalities and severe injuries, to parallel the County’s Vision Zero strategy and commit to being an active partner in Arlington County’s Vision Zero action;

2. Prioritize the safety of people getting to schools walking, biking, and taking transit, including school buses;

3. Enable increased walking, biking, using transit, including school buses, and carpooling to get students, staff, and visitors to school;

4. Commit to working with Arlington County to transition towards using public transit buses for middle school and high school general education transportation, including by coordinating on the routing and schedule of transit buses to enable more APS students, staff, and visitors to use transit to get to schools;

5. Minimize the use of personal motor vehicles to and around school buildings;

6. Ensure the transportation system is created and maintained with input from APS leadership and staff, Arlington County, and families and provides clear and consistent communication and transparency about its policies and performance;

7. Commit to work with Arlington County and the community to make school transportation safer, more efficient and more sustainable, including by developing and improving Safe Routes to Schools for people walking and biking;

8. Recognize that every transportation plan must account for all uses of the school building, including playgrounds and fields, gyms, voting locations, performing and visual art space, and public meeting space; and

9. Commit to teaching APS students about using safe and sustainable modes of transportation, particularly walking, biking, and using transit, in age-appropriate ways.

Consistent with those goals Policy Implementation Procedure (PIP), should give schools guidance on how to to achieve the goals of the policy.  Specifically, the PIP should:

• Stress the importance of safety in school transportation;

• Give guidance on the transportation demand management for students, which: 

• Encourages schools to plan Safe Routes to School for students walking - taking into consideration how students naturally approach campus and how they can get to the building safely;

• Encourages schools to plan Safe Routes to School for students biking - taking into consideration the routes that students use to bike to school and the location, supply, security, and comfort of bike parking;

• Encourages appropriate student use of transit, including the school bus system;

• Encourages schools to ensure that unnecessary private vehicle drop off/pick up is not the quickest, most comfortable, or most convenient way to get to/from school;

• Gives guidance on working with Arlington County to identify uses of the school bus system that could be replaced with or supplemented by public transit, such as regular bus routes, late bus routes and routes in between schools for middle and high schools; 

• Includes education around how to use safe and sustainable modes of transportation, specifically walking, biking, and transit; 

• Encourages participation in Walk & Bike to School Day, Bike & Walk to School Day, walking school buses, and bike buses; and

• Sets out minimum guidelines for communication around transportation, such as where families can find their bus stop, how families can learn of the iRide program, and who to call when there is a problem with school transportation (whether it needs immediate or longer term attention).

• Give guidance on the transportation demand management for staff, which includes:

• Subsidies and other encouragement for staff who walk, bike, take transit and carpool to schools;

• Commitment to giving staff who walk, bike and take transit access to storage for personal items and bathroom facilities to enable those modes of transportation, as appropriate and feasible in each school;

• Commitment to improving the availability, security and comfort (such as weather protection) for bike parking and to providing charging facilities for ebikes;

• Allowance for flexible work schedules, where feasible;

• Discuss how emergency procedures need to consider all modes of transportation, including, for example, the need for students who walk and bike to access coats in the winter, etc.; 

• Discuss ways car parking policies can serve the greater transportation demand management goals and priorities; and

• Commit APS to adjust any fees related to transportation (transit fares, bikeshare fees, parking fees) so that lower-income students, staff, and visitors pay less, while still serving the goals of this policy.

Unfortunately, the recommended revisions to the policy included in the July 26, 2024 memo from the Policy Review team falls far short of these goals. Most glaringly, the revised policy does not mention transportation safety. Consistent with the County’s Vision Zero policy, APS must prioritize the safety of students, staff, and visitors.

Furthermore, the revised policy does not recognize the adverse impact that motor vehicles have on our schools, our students, and our environment.  Biking and transit, the primary modes of transportation for students getting around on their own, are minimized in the policy.  The revised policy is also imprecise - it is not clear what the “Arlington County TDM Program” is referring to (Arlington County has a Transportation Demand Management Strategic Plan and a Master Transportation Plan).  The revised policy discusses “parking spaces” in a way that implies they are private car parking spaces, but is not clear (nor does such details seem warranted in this document).  Where the revised policy specifies neighborhood schools, it does not similarly state the policy for option schools and programs, thus, creating confusion.

In the same way, with the recommended revisions, the PIP sends the wrong message about APS’s priorities for Transportation Demand Management.  Again, safety is nowhere to be found in this guidance. The content of the revised PIP is primarily about car parking - the guidance on car parking comes first and takes up more than half of the document.  Moreover, the revised PIP takes a one-sized-fits-all approach to the guidance on car parking - establishing guidance that does not take into account the transportation network surrounding the school building and giving the same guidance to schools that are in residential neighborhoods with ample street parking to those that are within sight of MetroRail. 

Where the revised PIP discusses Transportation Demand Management for staff, it does not follow the best practices that Arlington’s own Commuter Services (ACS) urges for other employers.  Arlington staff should work with ACS to develop this section in line with best practices.  

Similarly, where the revised PIP discusses Transportation Demand Management for students, it does slightly better.  The revisions include guidance to “minimize the use of single occupant automobile transportation to and from school,” which is a step in the right direction.  However, this step is not applicable to most student transportation, as most students cannot drive themselves, and, thus, no motor vehicle that drives them to or from school would include only a single occupant. Unfortunately, this section also focuses on car parking and introduces the confusion of only discussing neighborhood high schools -- begging the question of whether student parking at the option high school or programs is, in fact, a right. Again, this section repeats the mistakes of the policy and rest of the PIP by barely discussing the the only modes of transportation most students can use on their own: biking and public transit. 

Finally, I send these comments acutely aware of the fact that, since the elimination of the Advisory Committee on Transportation Choices (ACTC), APS has not collaborated with APS families or the public on school transportation.  Before it was eliminated, ACTC had provided detailed recommendations on Policy E-5.1 Student Transportation Services and related PIPs, which I am attaching here.  Those recommendations were not reflected in the staff’s revisions of those policy and PIPs.  

I strongly urge APS to work more closely with families and the Arlington public on school transportation generally and on these policies and PIPs specifically. Transportation is the point at which families give children to the school system, using County infrastructure.  A successful school transportation system must be shaped by input from APS, Arlington County, and families and must provide clear and consistent communication and transparency about its policies and performance.

Please let me know if you have any questions or if I can provide further information or assistance.

Best,

Gillian

Note: all references herein to “biking” means using any personal micro mobility device, such as a bike, ebike or scooter.

Gillian Burgess

646-284-8894

Attachment:

ACTC Minutes – March 2, 2022

ACTC Minutes – March 2, 2022

ADDENDUM

Notes on TRANSPORTATION POLICY & PIP Revisions

Compiled by Gillian Burgess / March 2 2022

 

Pursuant to our discussion tonight, here are our notes on the revisions to the Transportation Policy & PIPs.

(Please excuse any shorthand, and let me know if there are any questions)

General feedback (Motion 1)

1.    There's very little in these about transportation other than school buses. The School Board policy should address *all* student transportation - including taking transit, walking, biking, & private cars.  It seems like the Safe Routes to Schools Program, including coordination with the County, should be in this Policy and these PIPs.

2.    We need goals for transportation. (see below)

3.    We should set some standards for the hub stop program. (see below)

4.    There's currently no way for families to opt out of school bus transportation (general - there's a note for SpEd). Seems like that should be built into these policies.

5.    Sometimes the school-provided transportation is not a big yellow bus, but a smaller vehicle. The documents should take that into consideration.

6.    There's not a lot about communication to families in these. It seems like these should be more clear about having clear communications that update as routes, etc update.

7.    There's nothing in here about students driving their own cars. Seems like something to be addressed (discouraged).

8.    The SpEd community has advocated for years to have more mainstreaming, including in transportation. We've discussed that sometimes SpEd transportation could be an attendant on a GenEd bus instead of a separate bus. This PIP should allow for that. (or even encourage it, where appropriate).

Goals

** The policy should set out the goals of student transportation (note that the document references monitoring process being made toward achieving the School Board's goals:

-       To enable students to get to school safely, ready to learn, in time to receive appropriate services (e.g. breakfast) and instruction.

-       To efficiently utilize public resources, including school buses.

-       To minimize the number of private cars coming to APS schools, including by encouraging students to take the school bus over private transportation, taking into consideration the duration of bus rides, drop off and pick up times, and encouraging students to use active transportation.

 

Hub Stops

Suggested hub stop principles; Unless not reasonably possible:

·  Hub stops should be located within every area bounded by "no cross" roads (unless no students could live in the area), with the exception that in single-family neighborhoods, up to [four] areas with "no cross" roads may share a hub stop. ("No cross roads" can be found here: https://www.apsva.us/wp-content/uploads/2017/09/Road_Classifications_for_WZ_Digital4-092517.pdf)

·  There should be more hub stops in denser areas of the County.  Hub stops with more than 20 students should be broken into two stops.  

·  Hub stops should not be located within a block of other schools' entrances.

·  Generally, hub stops should be located where there is public space (such as a park, library, church) and sidewalks where kids alight

·  APS should consider having routes run the same direction morning and afternoon, so the first to be picked up in the morning is the first to be dropped off in the afternoon, and vice versa.

·  The success of the hub stop program is measured by (1) the capacity utilization of the buses; (2) the number of buses needed per school; (3) the bus ride durations; and (4) the number of families driving to school

 

Specific Feedback (much overlaps with the general feedback above, most of the rest are for clarity)

For all documents: Consider usability – what are we using this for? Should there be a standardized format for the PIPs? Ensure that terms are used consistently, and that contact information is available for follow-up questions.

 

Policy E-5.1 Student Transportation Services.

1.    There's nothing about walking, biking & transit in the policy. This policy should encourage students walking, biking and taking transit to school. It should encourage APS staff to work with Arlington County to enable transit to school.

2.    Seems like goals should go in this document. 

3.    The School Board doesn't provide transportation, APS does.

4.    Does APS only require transportation as required by state & federal law? I thought we went somewhat beyond that?

5.    Students in option programs are entitled to transportation on the same terms as students attending neighborhood school. This document should make that clear.

6.    Re: other transportation being “at the discretion of the Superintendent” - shouldn't that include the limitation “in line with the Policy and PIPs”?

7.    There's a lot of missing details - e.g. when talking about routes, schedules and stops, the document should be clear that we're talking about school buses; there's a discussion of "transportation only [being] available" that should specify "school-provided transportation" (of course family-provided transportation will still be available)

8.    Consider organizing the "roles" section by actor - all roles of the School Board, the roles of the Superintendent, the roles of Office of Transportation Services (including Safe Routes to School), the roles of parents/guardians, the roles of students.

9.    ** This document should be clear that school bus transportation is provided based on safe walking distance from the property line of the (primary?) residence to entrance to school (some schools are not accessible from some parts of their property lines, e.g., where there are woods behind a school). 

10. Consider simplifying the presentation of PreK transportation; PreK - It seems the policy is to offer four-year old PreK transportation exactly the same as if the students were in K. So the walk distance for ES students should include four-year-old PreK, and the specific PreK section can be struck. Also, if a child turns 4 during the school year, do they then become eligible for transportation?

11. It seems like hub stop policy should be in this document.

12. The policy on parents/guardians transporting other people's kids in private cars seems off. Does APS need a policy on this? Would it be better presented as a policy on which students can be dismissed on their own, vs. students that must be dismissed to an approved escort? Also, where is the approval process that’s referred to?

13. "Bus Eligibility Zone" isn't defined in these documents

14. What is transportation to out-of-County schools? - it's referenced but not explained

15. What about transportation between schools for instruction (e.g. transportation to and from the Career Center)? I don’t see that in the policy or in the PIPs. Is there a standard for when students would be expected to walk/bike or take transit vs take a school bus? Should this be part of PIPs 1 & 2?

PIP 1: General Transportation (in addition to conforming changes to the Policy)

1.    Recommend titling the slide General *Student* Transportation

2.    Seems like Safe Routes to Schools should be in the roles

3.    How does school bus transportation work for students with two residences (e.g. divorced parents)? 

4.    What's the policy on students using school buses to get to after school locations other than their homes?

5.    Where does the APS code of conduct apply off school property? Bus stops? Transit to school? Walking to school? Maybe none of those?

6.    Which administrators are responsible for conduct on buses between two schools? (maybe we don’t need to specify)

7.    Do we really not allow eating or drinking on school buses? Are students allowed to drink water?

8.    " Do not bring large objects on the bus that will reduce seating or block aisles" - are large instruments not allowed on school buses?

9.    Bus routing should also take into account the aggregate duration of students' bus rides.

10. Do we really mean that neighborhood school bus stops may be up to 1 mile (ES) /1.5 miles (MS & HS) from a home? and that Hub stops can be farther?

11. What happens when establishing a stop for at least 5 students would mean the distance being above the maximums? 

12. Suggest adding language on bus stops to say that the location should be safe for waiting and for alighting, that crossing the street (if necessary for am/pm) should be safe and that there should be bike parking.

13. Young students: this part of the policy should be more clear. Also, do we really need to take students back to the originating school? If so, should the school bus routing generally be circular, same direction morning and afternoon, those with longer rides in the morning have shorter in the afternoon?

14. Do families know who to contact in the special situations, particularly students experiencing homelessness?

15. Seems like this should also reference the McKinney-Vento Homeless Education Act

16. Does this need a summer school section?

17. Would probably be better if PIP 1 and PIP 2 had parallel structure.

  E 5.1 PIP 2 Special Education Transportation Services

1.    The SpEd community has advocated for years to have more mainstreaming, including in transportation. We've discussed that sometimes SpEd transportation could be an attendant on a GenEd bus instead of a separate bus. This PIP should allow for that. (or even encourage it, where appropriate).

2.    I found the routing section to be particularly unclear.

E 5.1 PIP 3 Athletic, Extracurricular, Late Bus and Field Trip Transportation  

1.    Is there a standard for when students would take transit vs take a school bus (older students going to Metro-accessible locations)?  Is there a policy for providing transit fare for field trips? 

2.    Does the "equitable" formula used to determine the baseline field trip allocation take into PTA resources?

3.    For trips less than one mile, can we specify that students would be expected to walk or bike? Why the same distance for ES and MS/HS?

4.    The point about sharing buses is made twice

5.    Should there be more guidance about locations of late bus stops?  Why does the policy preclude late buses for ES? (We used to have them and could fund them again)

6.    Can PTAs supplement funding for late buses?

7.    Do we really want to put the times in the PIP (with the bell time study coming up)? Would it be better to make this more fuzzy, like saying "generally"?