The Governor's Announcement

When the charismatic Governor stepped up to the podium seconds after the begin of the much touted event about the Red Line the first parking lot of the West Baltimore MARC station was filled with dignitaries of all stripes from federal to local. They peered against the sun with a full view of the MTA bus hub and Amtrak and MARC trains passing through the station. Moore wasted no time and got straight to his message:

Governor Moore announcing Red Line restart
(Photo Philipsen)

This is a day that we’ve spent weeks planning for –A day my partners and I in government have spent months preparing for And a day that many Marylanders have spent years hoping for. Today I am proud to announce that we are officially getting the Red Line moving again here in Baltimore (Governor Wes Moore).
But in his short talk the Governor also said this: "While we are grateful for the effort in years past" that went into this project "this initiative is not about pulling something off the shelf and plug and play". He spoke about "keeping a keen eye on very meaningful societal shifts" and invited the people of Baltimore "this is the time to leave your mark" on this project.

In a WBAL interview with MTA Administrator Holly Arnold elaborated on next steps:

"We need to hear from the community, what do they want, do they want Light Rail or do they want Bus Rapid Transit, ...We are looking at a tunnel downtown and surface running options" (Holly Arnold on WBAL)

As happy as transit proponents can be about this shift in State transit policy towards expansion, the discrepancy between getting the Red Line moving again and the warning that this won't be "plug and play" combined with the invitation for open ended questions about mode and alignment leaves many questions about how much this is really a revival of the Red Line versus a distant new project in the same corridor. Mayor Scott expressed the situation clearly when he bemoaned that "today we should be cutting ribbons" and board trains, instead we are standing here with another announcement, however happy he was about that the project is slated for restart.

MTA Administrator Holly Arnold
(Photo Philipsen)

The New Starts Process

While "plug and play" seems logical as the quickest way of getting the project back on track, just dusting off the old project is not a feasible option, says Holly Arnold. It would run afoul of the requirements of the Federal Transit Administration overseeing a federally funded "New Starts" project. To get back into the New Starts process, the old "Record of Decision" has to be "earned" anew since the old one is no longer valid.

The Record of Decision (ROD) is the conclusion of the NEPA EIS process. The ROD document is prepared after the final EIS and identifies the Preferred Alternative. The NEPA implementing regulations (40 CFR § 1505.2) state that a Record of Decision should contain:
Statement of FTA’s environmental decision
Identification of all alternatives considered by the agency, including the preferred alternative(s)
Decision of all factors – economic, social, technical, environmental factors, financial considerations, and other New Starts considerations (23 CFR Part 771.127(a)).
Discussion of national policies that were balanced in the decisionmaking process and how each factor weighted in the decision
Explanation of whether the decision was designed to avoid or minimize environmental harm and, if not, why not

As MTA Administrator Arnold explains, data have to be updated leading up to a evaluation including a new "cost effectiveness" calculation, basically a cost-benefit analysis. As a first step the cost of the existing design would be escalated to a new expected construction period and the benefits be updated with new data, especially for ridership modeling, job access and equity as well as the expected travel time savings compared to the current baseline. According to Arnold, this work is well underway but it is too early to share the estimated new cost or the updated cost effectiveness.

The New Starts evaluation rating elements

Should the cost effectiveness ratio come out too low, it would be necessary to either reduce cost or boost projected benefits, namely ridership. That is where local government can play a big role by through transit supportive land use near stations which boosts ridership through maximal transit oriented development (TOD). Land use is one of the project evaluation criteria. On the cost side changes to the design may be needed to lower the construction cost, such as less tunnel which constitutes the lion share of the cost. Even bus instead of rail may be considered again. Administrator Arnold describes a path that will try to use as much as possible from the previous design while also making the project defensible under FTA's criteria.

Once a plausible and qualifying transit solution is found, it would become the "locally preferred alternative" (LPA) and the project could be put on the New Starts bandwagon again for a new Record of Decision and eventually a Full Funding Grant Agreement.

The Schedule

So, even in the best case that the old design would still pass all tests, a shovel can't get into the ground anytime soon, even though that is precisely what transit proponents would like to see.

Next steps display at the Red Line event (MTA)

Arnold expects the selection of a LPA in early 2024, not too far out, if that timeframe proves to be realistic. The promised study of an extension to Tradepoint Atlantic would run on its own schedule, but would eventually be also part of a New Starts process.

The last time around the process from conception to cancellation of the near shovel ready project took 13 years. Secretary Wiedefeld and Administrator Arnold want shave off much time by using an abbreviated process called a "supplemental NEPA document", not an all new environmental study and report (EIS). The supplemental approach focusses on what has changed since the last Record of Decision.

Arnold assures that MDOT and MTA are closely working with the Federal Transit Administration (FTA) on how to navigate such an expedited process and are "constantly thinking creatively" about the fastest path forward. Maybe one way of acceleration could be to decouple certain up-front aspects of the project from federal funding, but that option wasn't mentioned by MTA at this point. Current steps include hiring new consultants as needed to define, review and potentially design alternatives as they may be necessary to reduce cost or adjust to changed conditions.

The Challenges

From my 13 years on the Red Line team, I would identify at least six challenges that require a creative approach:

How to stick with the "supplemental" approach that updates demographic, economic and employment data as well as cost to whatever shifts there have been since 2013 when the last alignment decision had been made without slipping into the territory of an all new EIS.
The new Red Line: How much is it like the old Red Line?
(MTA Display Board)
How to bring the project back into the federal "New Starts" transit queue without being placed all the way at the back of the line. This type of queue jumping would be aided by language our congressional delegation put into the infrastructure bill, but it would be unprecedented. Besides, the 2015 estimate of $2.95 billion for a completion in 2022 would be more like $3.9 billion with a at least 10 year escalation.
How to ensure that the local partners (Baltimore City and County) become active partners instead of bystanders as especially the County had been in the last round. Locals have to preserve the right of way and make transit supportive land use decisions such as implementation of some of the station area community vision plans developed during the Red Line planning process which were part of the creative Community Compact between MTA, City, County, non-profits and communities. For local government to become reliable partners in the Red Line revival the Mayor and the Executive need to appoint Red Line specialists who pay undivided attention to this project.
How to transfer the previous design and engineering of tracks, tunnels, stations and the maintenance facility as intact as possible to a new set of engineers and transportation planners without spending $270 million again before the new teams become "comfotable" and are willing to assume the liabilities that come from signing off on a design.
County Executive Olszewski at the Red Line
announcement event (Photo Philipsen)
5. How to include communities as partners without opening the floodgates to all kinds of new ideas, rumors and groups that prefer anything but what is proposed as the baseline design. According to Arnold, MTA thinks of reviving the "community compact" introduced under Mayor Dixon and potentially remobilize the station advisory groups which had prepared vision plans for most station areas.
6. How to construct and finance the line? In 2015 it was assumed that about half of the project would be constructed by a design-build contract in the P3 mode (Public-private partnership) and the other half in the traditional design-bid-build mode. By contrast the Purple Line was offered entirely as a P3 with a private contractor refining the MTA offered design, then build and operate it and finance a portion of it. The high hopes that this would be a faster and less risky process have long been dashed with the Purple line experiencing one cost overrun and schedule delay after another. No they haven't cut any ribbons yet either. It will be interesting to see how MDOT Secretary Wiedefeld and Governor Moore assess the P3 option.

It is useful to remember that the Red Line was designed to run almost entirely in public "right of way" and that it doesn't require condemnation or demolition of houses. Complete Streets policies, now fully endorsed by the City, should make the integration of transit easier, since complete streets means a recognition of all modes, walking, rolling, taking transit and driving. A project being realized almost entirely in the public domain should be easier than one that requires a lot of land purchases and easements.

Still, in the last round the late baker and developer John Paterakis managed to force a station relocation so that the entry and exit of the Harbor East underground station would not have to be carved out of a corner of his property. This caused a crucial delay in 2013/14. In this round, the feds, the State, local government, private business and communities need to really support all aspects of the project to make it happen.

The restart of a project that is at least 14 miles long and had years of extensive public debate must focus on regional connectivity and not on minor local animosities. That is easier said than done: As in any larger infrastructure project, it is no problem to bring NIMBYs to the table and far more difficult to gather the support of the beneficiaries, i.e. future and current transit riders.

Still, even with a better understanding of the mandated procedures, three of the things Moore and Arnold mentioned publicly require special scrutiny:

"Meaningful societal shifts"

Yes, a lot of things have happened since 2013, notably the triple Baltimore handicaps that all came in 2015: The death of Freddie Gray in police custody and the unrest in the wake of it, the State orchestrated termination of the State Center Project and the cancellation of the Red Line. Finally COVID that changed travel behavior significantly. Still, none of this makes the preferred Red Line alignment selected 10 years ago any less necessary, viable, or desirable. Even the temporarily sagging ridership figures slowly approach pre-Covid levels according to MTA.

The only really "new" thing might be the unexpectedly successful TradePoint Atlantic which already brought express bus service to that location. It made the County Executive request the extension of the Red Line to the old Sparrows Point area. Moore already promised that this would be studied. However, even this wouldn't constitute a material change to the existing Red Line plans which had all along included the notion of a future extension to Dundalk.

Concept design for a new MARC Station (MTA/Amtrak)

Two other "shifts" are worth noting: Possibilities for transforming the "Highway to Nowhere" are much improved thanks to a $2 million federal "Reconnecting Communities" grant. Secondly, the new Frederick Douglass Tunnel is now partially funded with an initial $450 million tranche for design and construction of some small up front parts. The new tunnel replaces the old B&P tunnel ending just north of the West Baltimore MARC station which connects to the Red Line.

Both of these aspects are not jeopardizing the old Red Line design but allow the Red Line to become part of the precisely the type of catalytic change that the adjacent communities have long sought in the station area committees and elsewhere. MTA has begun conceptual design sketches visualizing the possible MARC station design within the existing Amtrak design contract.

BRT or LRT

BRT and LRT as alternative modes have been studied extensively as part of the 13 years of Red Line investigations. During the time of the Republican Governor Bob Ehrlich Bus Rapid Transit was the preferred mode and being explored in great detail. Comparative analysis showed that in the end a BRT in a tunnel is more expensive to build and to operate than light rail. Buses tend to break down more often than electric trains and need bypass lanes at stations to get around stalled vehicles. Seattle found this out when they initially built downtown BRT tunnels and later gave up on further bus tunnels. and expand their system with only LRT. BRT s more expensive in operation because the currently available buses don't have the same capacity as LRT trains and therefore require more vehicles and operators unless they would run fully automated. Urban transit with no transit staff on board is technologically possible, but hardly acceptable to riders in the foreseeable future.

Surface or tunnel

Surface running or tunneling was also extensively studied, for both BRT and LRT. It was the prevailing professional consensus that a full surface option would either be very slow (think Howard Street light rail) when running in mixed traffic or it would be very intrusive, when running in exclusive right of way. This would be especially true on Cooks Lane and Aliceanna Streets, where exclusive transit lanes

Initial Red Line rendering for Edmondson Avenue: The original
Red Line was designed to be entirely in its own right of way.

would hardly be acceptable to the residents and businesses, since those streets are too tight to allow designated transit lanes, car traffic, and parking to coexist in any meaningful way.

BRT proponents should also consider that we already have designated bus lanes in many places and must realize that they do not work in the same way as tracks in a designated area.

Conclusion

It is clear that conquering all these challenges and still get the project expedited for construction requires a tight rope walk. Not falling off the rope requires a unified voice that rallies around the already preferred, selected and designed and once fully approved project. This unified voice was briefly visible at the event in West Baltimore when speaker after speaker touted the Red Line as the best thing to move forward with. Adjustments to make the project defensible under FTA criteria should not be understood as a free for all to dust off the skirmishes from 10 years ago, especially not old hats that had already been refuted as unrealistic back then. While a few things have changed, Baltimore ist still Baltimore and the East West challenge remains essentially the same.

The unified voice is the only one that will be here in Washington. It will have to be loud and clear to overcome the formidable obstacles of line jumping and financing that currently stand in the way of straight up "plug and play".

Klaus Philipsen, FAIA

the article has been updated to include the P3 discussion.

The national publication The American Prospect wrote bout the Baltimore Red Line in this June '23 article

Maryland Matters wrote about reviving the Red Line in this June 23 article

Previous articles about the Red Line on this blog: