Local in Ann Arbor

Over 11 years after it was first envisioned, it appears that the dream of a parking structure and train station in Fuller Park is dead. A pointed letter from the Federal Railroad Administration indicates that the project as proposed is irretrievably flawed and no further action on Ann Arbor’s efforts to apply for funding is likely.

Neumann-Smith rendering of proposal; parking structure on left, station to right (gable)

The letter from the Federal Railroad Administration, dated August 11, 2021, must have arrived at City Hall with the force of an earthquake. Ironically, it was directed toward a man who was no longer there – Tom Crawford, our recently deposed City Administrator. The letter is brief and to the point. Here are the most pertinent points. They were written in paragraph form but placed in bullets here, emphasis added.

1. However, as FRA previously informed the City, the cost estimate for the City’s preferred project is an order of magnitude higher than other new intercity passenger rail and multimodal stations for which MDOT was awarded Federal funding by FRA to construct.
2. The cost is high because the City’s preferred location for the station is constrained and the City is proposing a substantial amount of parking, requiring the station to be located over the tracks.
3. In addition, the City’s preferred station design exceeds intercity passenger rail needs.
4. Therefore, FRA is discontinuing the development of the EA and does not intend to complete the environmental process at this time.

Mayor Christopher Taylor, who has been a major cheerleader for the station, predicted in early 2018 that the City of Ann Arbor would receive a go-ahead from the FRA by the end of 2018.  The City has been in long discussions with the FRA in an effort to comply with the requirements of the National Environmental Policy Act. NEPA requires a Finding of No Significant Impact (FONSI) that indicates a project will not cause environmental harm before Federal funding can be applied to projects. Once that finding was received, the City would be clear to seek grant funding for construction of the station. (The earlier grant was only for preliminary planning and design.) It hasn’t happened.

Point by Point

Here are the underlying facts behind each of the important points made in the FRA letter.

(1.) However, as FRA previously informed the City, the cost estimate for the City’s preferred project is an order of magnitude higher than other new intercity passenger rail and multimodal stations for which MDOT was awarded Federal funding by FRA to construct.

Translation: The cost is hideously high – ten times that for any comparable proposal for a new train station. The reference is to the ARRA grant of $198.6 million received by MDOT to improve and strengthen the Chicago-Detroit line (Wolverine route). This grant, administered by MDOT, is the source of the $2.8 million Ann Arbor has used to plan the FRS. At last estimate, the cost of both phases of FRS would be $171. 4 million (Final Cost Estimate). Compare to the cost of the Dearborn station, constructed with these grant funds for a cost of $28.2 million (open in 2014), and the Troy station, about $12 million (open in 2014; part of the cost paid by other transportation funds).

(2.) The cost is high because the City’s preferred location for the station is constrained and the City is proposing a substantial amount of parking, requiring the station to be located over the tracks.

Translation: Because of the insistence by the City that the location should be in Fuller Park, rather than any of the other sites considered (the current Depot Street location was much favored by many commenters), the parking structure is loaded tightly into the area currently occupied by the UM parking lot. That lot is situated in part of Fuller Park that has been leased to the University of Michigan. The UM has only temporary possession of it, since the lease must be periodically renewed. However, by virtue of this possession, a structure could presumably be erected on it to serve the UM. This has been clearly stated as an objective since the very first version of this project. (Note diagrams in our post, Fuller Road Station: It’s All About Parking. )

According to the Architectural Narrative (Neumann Smith, 2018), a total of 1332 parking spaces is planned (Phases I and II).

The proposed design. Note that the main section is the parking structure. The station (pink/orange) is poised over the tracks.

As noted in the letter, this immense amount of parking in a small space has resulted in the positioning of the train station over the tracks. It is so obviously a near afterthought.

(3.) In addition, the City’s preferred station design exceeds intercity passenger rail needs.

Translation: The design of the station, especially the requested parking accommodation, is based on a very large estimate of future passengers for the train service. But based on ridership for the intercity traffic (as distinguished from a commuter usage), this exceeds any reasonable estimate of people wanting to go from Ann Arbor to Chicago, for example. There are some subtle policy differences here. Amtrak service (which this project is supposed to support) is primarily an intercity network, though commuters may use part of the system. But commuter service is different and may involve entirely different management and even equipment. Indeed, MDOT attempted for some years to refurbish some used train cars to serve commuters. While the tracks are used by all rail providers (including freight trains), MDOT’s grant was actually to provide high-speed rail for intercity travelers.

Mayor Christopher Taylor has clearly confused these two uses of a rail system. In his 2018 letter to constituents Annual Report 2018, he predicted 1.5 million passengers by 2040.

Additionally, the Regional Transit Authority of Southeast Michigan (RTA) is proposing commuter rail service linking Ann Arbor and Detroit along the same rail right of way. Should the proposed commuter rail service be implemented, the RTA projects that an additional 143,320 to 229,950 passengers per year would use the station for work commute trips and other intra-metropolitan area travel. Combined intercity passenger rail and commuter rail passengers could result in nearly 1.5 million total passengers per year using the station in 2040.

We now know that commuter rail service between Detroit and Ann Arbor is unlikely to happen in the near future, since the RTA millage (2016) failed to pass, as did several attempts to revive it. But Taylor also exposed a conceptual error here, since the primary use of this grant program was not to support commuter rail.

Examination of FRA comments on a review draft of the Environmental Assessment reveal a concern with cross-talk on this conflation of the two types of rail travel and usage.

The core point here is that the projected rail travel does not justify this number of parking spaces, and therefore this immense parking structure. It has so clearly become a case of the tail wagging the dog, with the little train station nearly engulfed in a parking structure.

(4.) Therefore, FRA is discontinuing the development of the EA and does not intend to complete the environmental process at this time.

Translation: What is not quite said here but is certainly intended, is that the project is dead as currently configured. Since the NEPA approval is required to access Federal funds and it will not be coming and is no longer in process. That is it, finis, kaput. Or, with apologies to Jim Morrison,

A Long History

Perhaps the best starting point in understanding the history of the Fuller Road Station (FRS) is the letter to citizens of Ann Arbor sent by former Mayor John Hieftje on July 28, 2011. As we recounted in our post, Fuller Road Station and the Mayor’s Letter, Hieftje explained that the station would be built (located at the site of the parking lot on Fuller Park) as a replacement for the current Amtrak train station on Depot Street. It would be a joint venture between the University of Michigan and the City of Ann Arbor, with some Federal funds paying for the majority of the cost. But the UM would essentially pick up the matching funds. He stressed that

A big advantage of the financing plan for the overall community is that the University’s upfront contributions can meet the required local match for federal funding for the entire rail station…The Fuller Road Station, Phases I and II can be built without any significant upfront cost to the City.

Some millions of dollars expended by the City later, the basic theme has remained the same: We can build an elaborate parking structure with an appended train station with little local City money. The Federal government will pay for most of it and the UM will pick up the rest. And, importantly, the station must be built at the Fuller Road site.

An Early Hiccup

We have detailed the history of the City’s failed joint project with the UM in our post Fuller Road Station – A Review. Delays in attaining approval from the Parks Commission and the Council caused the UM to withdraw from the agreement in February, 2012. But a new vision quickly replaced that one. President Obama’s ARRA (stimulus program) awarded a grant to Michigan to implement Obama’s vision of high-speed rail. In September 2011, US Rep. John Dingell announced that Ann Arbor would receive a small fraction of that grant ($2.8 million) for planning a train station. (Note: Federal grants were made on an 80% Federal – 20% local match basis. The actual amount of the grant was $3.5 million, of which Ann Arbor must provide $700,000.)

Tough going

The communications with the FRA were evidently difficult as the City attempted to get approval of the preferred site for a new station in Fuller Park. The FRA required the City to look at different site alternatives, which required a separate analysis (Alternatives Analysis, Phase I, Phase II). As discussed in a May 2016 article in the Ann Arbor News, there were some changes in FRA management of this project. Attempts by the News to obtain information were answered with heavily redacted email text. Citizen FOIA requests were similarly answered with heavy redaction.

The City submitted its Environmental Assessment to the FRA in September 2017 and it evidently was subjected to some hard review. As described in the Ann Arbor News, a tough conference call in April 2018 involved many probing questions from the FRA and a surprise requirement to engage in an archeological study. This required an additional cost, another consultant, and another delay. The study was completed in October 2018 and no further action was required. This was the comment: “none of these sites appear to be associated with important events or patterns of history, or with individuals significant in local, regional or national history.”

There was also extensive public comment, much of which stressed unhappiness with the choice of the Fuller Road site rather than the existing location on Depot Street. Ann Arbor staff and consultants were required to respond to these comments as part of the EA process, but the comments and response are not shown on the City’s web page for the project. The last update to the City’s Ann Arbor Station web page indicated that a revised EA was being reviewed as of June 2019.

At What Cost?

The promise that no City of Ann Arbor funds would be spent was abandoned some years ago. The actual period of the grant ended on September 30, 2017, after which the City was working on its own dime (could not apply any expenses toward the grant). This was well covered by the Ann Arbor News and we asked whether the Council was ready to gamble (they did).

This article details a number of the projected costs.  It mentions the embarrassing gaffe that the project team made in failing to add up the figures. (Rita Mitchell, a citizen volunteer, brought the error to their attention.) In recent years, the Council has been obliged to vote on additional funds to complete the EA process.

Notably, the project has stayed at the top of City budget priorities, in spite of the eye-popping numbers. The Capital Improvement Plan (CIP) is the best report the City’s financial departments are able to produce, showing both the timeline and the projected costs of capital projects. The Ann Arbor Station has stayed at the top priority for years, and is still there. But the schedule has slipped.

The CIP is intended to show costs in “all funds”, including local and external. Note that for the NEPA activities, all have already been spent (click to enlarge the figure). We are currently in FY 2022, and the total is shown as $2,386,000 (figures must be multiplied by 1000). This is not the complete cost of our activities because that is less than the amount of the grant, and we know that was exceeded. Final design (which would require new funding) is intended to begin in FY 2023 (next year) and planned to cost $14,700,000.  The station construction is shown to begin in FY 2026 and to cost a total of $86,068,000. Of course, without grant funding (which was never guaranteed but is now impossible), this will not happen.

Taylor has continued to suggest that the Federal government will pay 80% of the cost of any construction. But of course, there has to be a program. The TIGER program expired several years ago, and until our new rail-loving Secretary of Transportation makes some announcements, we don’t know of a current program by which Uncle Sam would buy us a train station. Also, most programs are competitive and it is not clear that this project would be successful, for many of the reasons stated in the FRA letter. In any event, without compliance with NEPA, the project is simply dead in the water.

And 20% of any program in the tens and hundreds of millions is still a lot of money. It has always been hinted (or said directly) that the UM would pick up a big piece of the costs for matching funds. Other “partners”, like the AAATA (which has its own funding problems) have also been suggested, but basically the question of how the City would pay for millions in matching funds has essentially been answered by hand-waving. Finding partners for $24 million or so might be challenging.

The Fatal Flaw

So what went wrong? Aside from a number of over-optimistic projections about commuter rail, etc., the true problem is that this project was always about parking for the UM. It began with the effort to keep a parking structure from bothering neighbors on Wall Street (long since constructed) and ultimately grew to a size and configuration that was impossible to defend as a transit project. Though the high employee count at the UM Hospitals was used to justify the possibility of an eventual commuter train, in reality the UM hospital staff agitate for more accessible parking. (The City Council just renewed the lease for the three parking lots once again.)

We could speculate about the connection between our Mayor’s insistence that the “station” will be built and his close ties to the UM, but there is no evidence that any direct pressures have been brought to bear. In any event, it is clear that the UM and its need to expand parking have played a large part in the design and placement of this overblown project.

What now? Indications were that City officials may be having conversations with MDOT and others, seeking to breathe life into the project. They are unlikely to succeed, given the finality of the letter from the FRA.

NOTE REGARDING COMMENTS: It has long been our rule that commenters must give a true name in order to participate. Some comments have been received that are excellent comments, but are anonymous. I dislike taking down comments after they have been posted, therefore we have now instituted moderation of comments. Comments should also be relevant to the subject of the post, and otherwise follow our previously posted guidelines. (See About.)

ADDENDUM:

Many readers may have missed the excellent blog, All Aboard on Depot Street. I certainly did. Because of programming decisions, the Home page does not take the reader to recent posts. They can be accessed from this page. (Note: this site is not secure and your system may give you a warning.)

You’ll note from the post that I have referenced here that the FRA has been sending the City messages about the inadequacy of the proposed project for some time. A document is shown here that dates from 2018. It expresses many of the same objections and concerns that were stated in the “goodbye” letter, in almost the same language.

This paragraph is from a message sent by Melissa Hatcher, who was managing the EA review, to Eli Cooper (the Ann Arbor staff who has been the major contact for this project) and Michael Nearing (the city’s project manager for infrastructure). The letter in general is urging a rethink of the PE (engineering) plan because of the excessive costs.

As best we can surmise, there was no action taken as a result of this letter. There was no rethink of the project and there was no publicly discussed effort to reconsider the project. It appears that the strategy was “hold on and hope”.

It is notable that essentially the same information was sent in the August 2021 letter, but this time it was sent to the Ann Arbor City Administrator, presumably the top individual in the organization. So the current letter is the proverbial club to the head. “Get this???”

UPDATE (September 5, 2021): Some interesting afterthoughts by John Hieftje, the former Mayor, quoted here. He accurately notes that in those early days MDOT was leasing rail cars to establish a commuter train system, which seems unlikely now.

“It was a different scenario back when I was hoping to get this project built,” he said. “The world’s a different place.”

SECOND UPDATE (October 13, 2021) Apparently supporters have prevailed on Congresswoman Debbie Dingell to go to bat for the Fuller Road Station. We can only hope that it has little effect, as it should. There are committees. Appropriations are required. Transportation funds are always limited. And this is just a bad, overblown idea.