Testimony of Transportation Riders United
on the Recertification of the South Eastern Michigan Council of Governments
as the Regional Metropolitan Planning Organization

Summary: The purpose of designated Metropolitan Planning Organizations (MPO) is to establish a coordinated, continuous, and comprehensive framework for making transportation investment decisions in metropolitan areas. Transportation Riders United (TRU) believes that Southeast Michigan Council of Governments (SEMCOG), the MPO for this region, has not fulfilled those responsibilities. SEMCOG has been designated as the regional MPO since 1967, during a time of massive suburban highway expansion, runaway road and bridge deterioration, increasing highway congestion and decline of public transit service and infrastructure. SEMCOG's current and continuing lack of leadership and action has denied the City of Detroit, the older suburbs, and the entire region the benefits of the 1991 federal ISTEA, and the 1998 TEA-21. These path breaking acts allowed flexibility in planning for not only highways but rapid transit, pedestrian and bike trails.

Below is a list of specific concerns that TRU has, related to the federal requirements for MPO certification.

1. Roles and Responsibilities:

A. Voting structure: A major concern that TRU has is in the design of the voting structure in the SEMCOG bylaws (Article III, Sections A.3 and B.5.a) The voting structure for General Assembly and Executive Committee resolutions requires, firstly, a vote of delegates based on municipality membership, which is weighted heavily in favor of a suburban and fringe region vote. Only if an item is passed in this vote can a request be made to re-vote under the population-weighted vote procedure. In this way, resolutions that are favorable to inner urban interests, but unwanted by suburban interests, are likely to be defeated and remain defeated without recourse.

RECOMMENDATION: SEMCOG should be required to change its bylaws to allow population-weighted voting when requested any time, including as an override of a failed resolution.

B. Delegated Public Participation: The Detroit Department of Transportation (DDOT) has no public participation plan. TRU has been informed by DDOT that DDOT delegates its public participation planning to SEMCOG. However, when TRU has asked SEMCOG officials about this issue, they answer that SEMCOG has no responsibility for DDOT's plan development. When TRU asked SEMCOG about who is responsible for holding hearings regarding fare increases and route changes, SEMCOG states that it is not concerned with site-specific plans (i.e. future transit centers). The result is that hearings are not held and no one takes responsibility for including public participation. TRU is unaware of any notice postings regarding SEMCOG hearings posted in any buses. There is a need, at a minimum, for clarification of SEMCOG's responsibility, if any, and DDOT's responsibility with regard to a DDOT public participation plan.


RECOMMENDATIONS:
1. That SEMCOG, SMART, and DDOT have clearly delineated roles in public participation with SEMCOG and DDOT representatives present at each other's hearings.
2. That SEMCOG have at, a minimum, two series of hearings per year (in City and suburban locations) to help it and the transit systems coordinate service. These hearings should be posted on SMART and DDOT buses at least 30 days before the hearings, and that a written response to the testimony be made public 30 days after the hearings.

C. Where "Real" Planning Occurs: the SEMCOG Transportation Advisory Committee (TAC) meetings which include many of the key regional stake holders are followed by closed door "technical sessions" where only invited members make the decisions. TRU is a TAC member but has been barred from attending the post-TAC sessions. TRU attends the SEMCOG Executive Committee meetings and testifies when a TAC decision has changed from its understanding at an earlier TAC meeting. It is clear to TRU that planning takes place in the post TAC meetings which impacts the region and which does not have the benefit of full regional representation.

RECOMMENDATION: That all meetings held by SEMCOG be open to members of advisory committees and the public, and that SEMCOG bylaws be changed to reflect this more "public role" of the organization.


2. SEVEN PLANNING AREAS: As explained below, TRU believes that SEMCOG has failed in the seven planning areas in relationship to public transit systems. Many organizations, including SEMCOG's affiliated Metropolitan Affairs Coalition, have recommended that the metro Detroit area be served by specific transit expansion projects. However, SEMCOG has not led a meaningful coalition in support of any of these projects, which could have resulted in federal "New Starts" funding for the region. Rail-based proposals and studies, in particular, have been discouraged by SEMCOG over the years. SEMCOG does not employ a full time planner who specializes in transit, and planning for pedestrians and bicycle trails is absent, or inadequate.

A. Support the economic vitality of the metropolitan area, especially by enabling global competitiveness, productivity, and efficiency.

1) TRU has not seen any support for or coordination activities by SEMCOG in relation to the Detroit Department of Transportation (DDOT) and SMART bus systems. The routes for buses are often duplicated between the two systems, and a joint Greyhound/Smart terminal is planned for downtown Detroit, while DDOT is building a separate terminal and renovating its three garages. This results in taxpayer dollars being misused in an uncoordinated way, and unnecessary duplication of services. A joint governmental agreement has recently established the Detroit Area Regional Transportation Authority (DARTA), which may at some point in time be responsible for transit coordination. The effectiveness of this organization is yet unknown.
a) SEMCOG admits that it "does not tell the transit systems what to do" and provides information. However, SEMCOG does not suggest improvements or even attempt to coordinate transit for the area. This was evident at the recertification hearing when an FTA official questioned the transit systems, SMART and DDOT, about whether they have attempted to share fuel costs or share maintenance garage space. SMART Director Dan Dirks said that this would be impossible due to the agencies' collective bargaining obligations. However, TRU has spoken with some local union representatives and they were unaware of any proposals to coordinate resources. This "blame the unions" response is nothing more than an excuse to avoid coordination responsibilities. SEMCOG, SMART, and DDOT have not made any attempts at coordination. SEMCOG suggests that coordination occurs at monthly partner meetings with SEMCOG and the transit systems. TRU is unable to evaluate what occurs at these meetings, because they are not open to the public. TRU can verify that DDOT and SEMCOG representatives do not attend SMART Board meetings and SMART and SEMCOG representatives do not attend DDOT Advisory Commission meetings. It appears that there is very little if any communication, let alone coordination between SEMCOG and the transit systems. SEMCOG does not view the transit systems as its business.
b) SEMCOG has had no role in the planning for the separate SMART and DDOT
transit centers. In fact, it does not even include the transit center on its planning maps. SMART argues that it would lengthen bus routes for it to use DDOT's proposed terminal. The only way that this makes sense is if SMART also uses its proposed terminal. Providing stops across the street, away from other buses only makes bus riders have to face the danger of crossing a busy street because DDOT and SMART refuse to work together. (See discussion of Keep It Moving study below) SMART has indicated that it prefers to decentralize its operations, however, this is frequently a SEMCOG-endorsed euphemism for doing away with line-haul buses in favor of dial-a-ride service, which reduces transit choice for all riders.
c) The transit dependent suffer as a result of this lack of coordination. As evidence of this lack of coordination was the DDOT transit center change from Cadillac Square to Capitol Park December 2001. Notice of and hearings regarding the change were completely lacking. To date, there is still no place to buy bus passes or pick up schedules in Capitol Park. DDOT has placed some bus schedules in the corner of a convenience store. However, the store's hours are limited and the bus schedules are usually poorly stocked. DDOT does not have a system wide map available to bus riders. DDOT has only recently printed a small diagram showing where the buses stop around Capitol and Grand Circus Parks (Capitol Park is too small to accommodate all of the buses.) Capitol Park has an ongoing rat problem and graffiti is omnipresent as is drug dealing. Oddly enough, DDOT maintains a transit center in Cadillac Square that is open during business hours to buy passes and pick up schedules. Detroit Mayoral Representative Derrick Miller's comments that Capitol Park is an acceptable transit center is false. Any walk through the area evidences this conclusion. The transit center change to Capitol Park is a matter SEMCOG could have coordinated, but did not see it as its concern.

2) Planning for Public transit has not been forwarded by SEMCOG as a solution to any of the traffic congestion problems faced by residents.

RECOMMENDATIONS:
1) That SEMCOG be required to assess in a meaningful way, consistent with the procedures used for highway proposals, the possible role of public transit in solving many of the problems that roads and expressway changes are proposed to solve.
2) That SEMCOG assume a leadership role in coordinating the SMART and DDOT organizations during the startup period before the Detroit Area Regional Transportation Authority (DARTA) develops and implements its service plan.
3) That SEMCOG be made responsible for monitoring and reporting to the FTA the
effectiveness of DARTA on an on-going basis.

B. Increase the safety and security of the transportation system for motorized and non-motorized users.
1) A Joyce Foundation report, Keep it Moving, reports that Detroit has the highest rate of pedestrian fatalities among cities of more than 500,000 persons. The pedestrian fatality rate is higher for people of color than for whites. African Americans walk 82% more than whites and Hispanics walk 58% more. Are the pedestrian deaths related to the lack of a coordinated and timely region wide transit system? SEMCOG does not keep data on the number of car/pedestrian fatalities, but uses the numbers to support planning for additional right and left turn lanes. SEMCOG uses additional turn lanes and capacity expansion to solve safety problems.
Safety and security is not only related to highways, but to the way a transit system works. DDOT moved its transportation center from Cadillac Square to a poorly lit area with few bus shelters and no information about the locations of the bus routes. Did SEMCOG have a role in helping plan where transit centers are located? Both DDOT and SMART place bus stops in mid-block, which often results in riders "jay-walking" to catch transfers. From a safety standpoint, this is a dangerous planning technique.

RECOMMENDATIONS:
1. SEMCOG should place greater emphasis on pedestrian safety and security within its transportation-planning role.
2. SEMCOG should attend to the "rails to trails" movement, and develop plans for bicycle paths and lanes as a part of the planning process.

C. Increase the accessibility and mobility options available to people and for freight; specifically identify freight shippers and users of public transit on list of stakeholders to be given opportunity to comment on plans and TIPs. [1203(h)].

1) Senior Citizens and Disabled Needs For and Use of Public Transportation: SEMCOG has not discussed the specific needs of the large number of senior citizens and disabled people who live in the region as apart of its planning process.

There has been a school of thought that sees public transportation as a resource only for the disabled, senior citizens and the poor. If these clients are the major focus for a transportation system, then, the proponents of this philosophy see that "para-transport" and employer-funded buses will be sufficient.
In fact, the needs of the elderly, persons with disabilities and people in low wage work are as variable as the needs of the rest of the community. Many seniors do not have disabilities and want to use a transit system for shopping, church, visiting friends and relatives, as well as going to the doctor. In a needs assessment funded by the City of Detroit and carried out by the Wayne State University Institute for Gerontology, 46.4% of the seniors were concerned with how to get to health care. Only 63% of the seniors have both a car and a driver's license. 37% of the seniors must depend on other people or other ways to get to health care services. The seniors who are most vulnerable because of disabilities, are 75 years or older and live alone, are more likely to be without personal transportation; between 25,000 and 32,000 of such people in the City of Detroit do not have adequate access to transportation. For those persons, para-transit may be necessary. However, for seniors, their difficulties with the transportation system are just like the difficulties of the general public: long waits, no bus shelters or benches, and suburban lines that do not stop or pick up in some communities.
Many services for the elderly have been forced to provide their own transportation. In a survey of the 37 programs and organizations funded by the Detroit Area Agency on Aging most of them reported that transportation for seniors is one of the highest needs, followed by needs for in home services, and the expense of prescriptions. This is in spite of almost 2/3 of the programs owning and operating buses and vans. The impact of inadequate transportation for senior citizens is dollars being spent on transportation instead of programs.
For people who are mobility impaired, para-transit may be the only answer. However if that system is crowded with persons who could use regular transit (healthy seniors) then it will be less available for those who really need it. In Detroit, "Metro Lift" is available seven days a week, 24 hours a day. However, appointments must be made a week in advance for the service.

2) Effective and efficient movement of freight in and through metro Detroit is a key to economic sustainability and growth. SEMCOG is only beginning to become involved in freight movement issues, and then primarily with regard to trucking. SEMCOG has no freight-specific committee. Metro Detroit has a difficult geographic setting for efficient rail freight movement, but nonetheless has many bottlenecks which could be removed with the local support and championing of SEMCOG. Detroit is one of the most important points of freight transfer from Canada to the United States because of the changes in international trade relationships (NAFTA).
Every ton of freight that could be efficiently moved by rail relieves the congested highway system of trucking requirement and opens the space to passenger car movement. Metro Detroit's rail infrastructure is in place and any physical, commercial or regulatory capacity constraints need to be removed to maximize its utility. Planning should include alternatives to highway expansion, such as I-94 and I-75, such as whether enough has been done to promote truck removal from highways through facilitation of rail freight movement on the corridor.
In addition, in other parts of the country, the freight rail industry and passenger rail industry have found ways to work together on capital investments to their mutual benefit, and public benefit. Amtrak service suffers in this region still, because of a few key bottlenecks which lengthen trip times and reliability. Fixing capacity constraints improves both the movement of freight and people.

RECOMMENDATIONS:
1. SEMCOG should include an impact information on seniors and disabled in all of its planning, and coordinate planning activities with the three area agencies on aging that plan for services for senior citizens in the seven county region, by involving their leadership in decision making.
2. All of the stakeholders - elderly, disabled, freight, etc. must be involved meaningful oversight of the planning process
3. SEMCOG should take the regional lead in promoting freight rail movement, and coordinating with the various U.S. and Canadian freight rail entities that operate in the region, as well as Amtrak and VIARail.



D. Protect and enhance the environment, promote energy conservation, and improve quality of life.
Several areas in the metropolitan area are on the edge of non-attainment, and air quality will continue to be a problem in the hot summer days. There has been a slight increase in the number of "Bad Air Days" up from an average of 13 each year during 1990-94 to 14 each year during 1995-99.
Air quality issues have a disparate impact on African Americans whose children are hospitalized for Asthma at a rate 3 to 4 times the rate for white children. And, the figures for 1998 show that African Americans are almost three times as likely to die from Asthma. The constant emphasis of SEMCOG on highway expansion without including rapid transit issues as an alternative will only increase these terrible figures. Motor vehicles emit 1/3 of the nation's carbon dioxide, and 40% of nitrogen oxides, and most of the carbon monoxide. APTA estimates that a five mile commute in a car annually releases 110 pounds of carbon monoxide into the air, and the same commute on a train releases only 2-4 ounces of the same pollution per passenger.

RECOMMENDATIONS:
1. All SEMCOG Planning should address the impact on air quality, and the likely increase in risk of mortality and morbidity from asthma, as well as other diseases caused by poor air quality
2. Because of the demographic make up of the region, SEMCOG should demonstrate that the regional transportation plans and investments comply with Title VI of the Civil Rights Act of 1964, including congestion mitigation strategies.

E. Enhance the integration and connectivity of the transportation system, across and between modes, for people and freight; coordination of federally funded non-emergency transportation services in metropolitan planning areas, e.g., welfare to work. [1203(d)]
1. The two major transit systems, DDOT and SMART do not coordinate their routes or services as noted above. In addition there is no transportation map for the region, the stops do not indicate the route numbers that will stop, and there is no single transportation map for the DDOT. The lack of coordination between the systems is a barrier to employment (see attached articles about low wage earners and transportation.)
3. SEMCOG has taken no leadership, no role in enhancing integration and connectivity of the transportation system for riders. This has a disparate effect on those who use public transit in order to go to work. Long, often late, uncoordinated bus rides are the best; total absence of access by pubic transit to jobs has created barriers to job seekers far too often.

RECOMMENDATION: Please see the recommendations on page two, under Item A.

F. Promote efficient system management and operation: Information cited above (about the absence of evaluating public transit alternatives, bicycle and pedestrian issues as a part of reviewing proposed highway expansion and the duplication of SMART and DDOT terminals and routes) are evidence that SEMCOG sees its transportation planning role as automobiles and highways, not bikeways, pedestrian walkways and safety, and certainly not public transit.
1. SEMCOG's current planning system does not reflect the integration or "coordinated, continuous, and comprehensive framework" suggested in the most recent amendments the legislation, TEA-21.
a) Urbanized areas: The census sets boundaries after census every 10 years; after the 2000 Census, the area for SEMCOG for urbanized areas is smaller than previous years. Boundaries are used to differentiate rural roads from urban roads for purposes of expenditures. The result of the so much farmland being included in the "urbanized" boundaries is that sprawl has been created in the areas that were not really urban, but in fact rural, though within the "Urbanized Area Boundary. '
Census bureau trimmed the "urbanized area" down after 2002 census, as they realized the amount of farmland in the previous boundaries of the "urbanized area." SEMCOG fought this decision, and a rule change resulted. In fact when a SEMCOG Board member asked that the discussion about "Urbanized Boundaries" be reviewed in terms of economic impact on the whole region, SEMCOG responded that "it was a technical, nothing to do with economics or sprawl, so would not be reviewed in terms of economic issues."
Growth is where increase in population that area cannot hold. Sprawl is development in rural areas with simultaneous dis-investment and abandonment of the urban core. TRU believes that SEMCOG's definitions of planning, urbanized areas, absence of attention to pedestrian, bicycle, freight coordination and public transit has contributed to sprawl in the region it purports to plan for.
b) Planning Process and structure: SEMCOG has not revised its planning structure to reflect the designs of ISTEA or TEA21. SEMCOG admits there is no formal process for establishing priorities in the planning process. There are apparently no regional goals for planning to be based on. SEMCOG has eight federal aid committees left over from pre-ISTEA era. This lack of action in changing the planning structure has contributed to the decline of the region.
TRU's understanding of the current planning process is that it begins with the very private and entrenched county road commissions. Ideas are solicited from local communities as to what they want for transportation in the future. When a representative of a regional environmental group called Oakland county to find out about the meeting of the federal aid committee, so she could attend and raise issues, she was told the meeting was confidential. The way planning is done, now, is that rather than picking the best projects for the entire region, each community (seven counties plus Detroit) gets to put forward the projects it wants most. It appears to TRU that "Keep everyone happy, because they might get up and leave SEMCOG" is the over-riding value, meaning the value is to keep our structure alive, rather than rational regional planning.
SEMCOG does NO Regional Planning. The game is for each local community to "bring out your projects," and then the lists of projects are compiled by SEMCOG. The list of projects in their area is given to each of the eight federal aid committee, as a pass through from SEMCOG. By the time it gets to the federal aid committees it is too late. People must be involved when at the initial stages of planning, the public is denied participation where it would be most useful.
c) SEMCOG uses an arbitrary scoring process to evaluate projects in the TIP and the 25 year plan. Each project in each "swath" or transportation corridor is ranked 1,2, or 3; bridges were ranked 0,1,2,or 3. The explanation from SEMCOG is that you might not have to replace every bridge in the 25 year planning cycle, but, you WILL have to resurface every road. For transit the range of 0 -3 is used, arbitrary numbers.
Once the number is on paper it takes on a life of its own. There is no rationale or basis for these numbers. The SEMCOG planning process is designed to keep things in separate boxes, not an integrated regional plan. Safety issues are talked about separately than other issues. When asked how safety issues are looked at in each project rating or selection criteria, SEMCOG officials said it does in the "project swath" ie the long range plan, but not in individual project selection, unless "safety dollars" are trying to be used or applied for.
The metropolitan Detroit area has un-regional, un-integrated planning, with no goals to be planned against. TRU believes there must be goals, and they must be operationalized into objectives and then the criteria against which EVERY project is measured.

RECOMMENDATIONS:
1. SEMCOG be required to revise its planning structure and process to reflect the language in ISTEA and TEA-21, to assure that a regional view has the highest priority, not a crazy quilt of local projects.
2. SEMCOG be required to set a system for evaluating projects in the TIP which will reflect all of the criteria: safety, alternatives to highway expansion, etc,. In addition, if a numerical system is used to prioritize projects, that system itself should be open to public comment as to the criteria.

G. Emphasize the preservation of the existing transportation system.
Michigan Governor Jennifer Granholm proposed that "fit it first" should be the plan before highways are expanded. TRU does not know the position that SEMCOG took in the subsequent legislative battles. However, absent a plan or set of goals, it seems unlikely that SEMCOG had the policy basis for a position. TRU believes that if there were a coordinated regional plan in place, that SEMCOG could have taken a position that "fit it first" was a rational step to take.
Preservation of the existing public transit systems is at the mercy of the two major systems (DDOT and SMART) abilities to maintain themselves. Without leadership from a regional body interested in coordination, each system will try to maintain itself, possibly at the expense of the other.

RECOMMENDATIONS:
1. SEMCOG should have a coherent vision of the region so that it can provide local and state leadership to initiatives that have an impact on the region.
2. SEMCOG should also support local communities that are interested in innovative traffic plans to deal with safety and congestion.

3. Public Involvement: While members of transportation advocacy groups are appointed to the TAC there is no organized way to reach out to those who use public transportation to involve them in decision making. In addition, the way that decisions are made about plans and investments means that a concerned individual must be involved in the earliest steps, the county road commissions, which are the first step as a result of the Memoranda of Understanding with SEMCOG.
A colleague from an environmental group who was concerned about a project recently told TRU leadership that she could not get information about the time and place of the Oakland Co. MOU meetings or how her concerns could be heard.
SEMCOG has not encouraged persons with disabilities to be involved in decision making. Meeting Agendas are not on their web site so that they can be enlarged and downloaded for visually impaired persons. An Americorps volunteer, who is with TRU, and who is visually impaired was discouraged from using a tape recorder for her own personal records at a recent SEMCOG meeting.

RECOMMENDATION: SEMCOG should show how it is complying with the ADA, and how it's planning process and investments reflect the needs of the disabled.

4. Economic Justice: SEMCOG has been weak in the EJ analyses. SEMCOG lack of attention to these analyses exacerbates the economic and racial problems in this metropolitan region. As described above in the discussion about SEMCOG's lack of coordination of the Region's transit systems, SEMCOG continues the status quo. SMART and DDOT play their respective roles in the suburbs-versus-the-City war, in what has been described as one of the most racially segregated regions in the country. With the little transit that we have, SMART and DDOT with SEMCOG's wink of approval continue our racially segregated systems. Separate, but equal is the norm for the bus systems. SMART and DDOT do not work together even when economies of scale make sharing resources advantageous. Instead of trying to ameliorate this situation, SEMCOG knowingly approves of this waste of time and money. So, we have transit systems that cost too much and provide too little. Of course, this impacts the poorest citizens of the region who are dependent on the bus system the most. SEMCOG's neglect of our transit systems seals the separate, but so unequal system that our Region has created.
This costly segregation of our transit system coupled with the SEMCOG voting system that causes precious transportation dollars to be spent encouraging sprawl results in the Region's poorest citizens subsidizing their own neglect. Taxpayers in the City of Detroit and in the older suburbs do not receive their fair share of transportation dollars and taxpayers in the outer-ring suburbs receive more money than their population warrants. This results in citizens at the poverty line working to pay for expansion of affluent communities while having their own communities needs not met. This travesty is what SEMCOG sees as normal and in fact plans to continue it. SEMCOG has decided that poor areas will remain poor and then divests additional money from those areas. SEMCOG describes this decision-making process as being realistic about growth. However, SEMCOG's processes actually cause the investment and disinvestment to occur. TRU waits for the day when neighborhoods in the City of Detroit will be reviewed to determine how best to reduce poverty and increase living standards. SEMCOG does not see citizens in poor areas as its concern.

RECOMMENDATION: As outlined earlier, SEMCOG should provide meaningful criteria for economic justice analyses including impact on air quality (health issues), employment, and safety. The criteria should be developed in line not only with the Civil Rights acts and the ADA, but with a vision of an region that is green, inviting and easy to travel around. Economic Justice criteria should not just be regulation based, but based on values and principles.

5. Major Investment, Feasibility Studies : TRU is aware that SEMCOG has commissioned a number of feasibility studies about rapid transit. To our knowledge, they have not been formally reviewed or used. On the "street" it is said that any public transit studies are sent to SEMCOG to die. This is a major waste of taxpayer dollars.

RECOMMENDATION: Any Studies paid for by SEMCOG should include a public hearing related to the results, and a formal place on the TAC agenda as a part of their disposal.

Finally: In a 1999 letter to SEMCOG, Mr. James Steele of FHWA encourages "a continuing, cooperative, and comprehensive transportation planning process that results in a region wide transportation vision and plan that considers all transportation modes and supports sustainable metropolitan community development and social goals. " In addition, the recommendations made as a part of the recertification process in 2000 include statements that SEMCOG take a stronger role to encourage and assist in coordinating SMART, DDOT and DTC. In addition, TRU charges that neither of these recommendations have been dealt with at all.

ATTACHMENTS:

1. SEMCOG Population Voting Ratios
2. Newspaper article about the difficulties with public transportation