October 8, 2020

Analysis: Bus Riders and the State Fairgrounds Deal

By Detroit Peoples

Analysis On the recent City Planning Commission vote on the State Fairgrounds Development Deal

October 5, 2020 


On October 1st, 2020, the City Planning Commission voted 7-1 to approve changes to the City of Detroit Master Plan to reclassify the State Fairgrounds from “regional park” to “light industrial.” This resolution will now go to City Council for consideration – in which they will have to approve rezoning and approve the sale of 147 acres of public land to private developers Sterling Group and Hillwood. This is related to an announcement from the administration that a proposed “North Transit Center” will be built near where Amazon may open in Detroit – despite not being named in the Purchase Agreement.  The Purchase Agreement lays out the process for selling the land, and only lists “tenant facility.” In short, the city is considering selling land for a possibility that Amazon will open a distribution center that will hire 1,200 people, with a flimsy promise of job workforce development in lieu of meeting the 51% Detroit hire required by Executive Order.

The Transit Justice Team participated in two City Planning Commission meetings, the first of which took place on September 24th – which lasted until 12:30am the next day. The mayor’s office recommended a vote that day and there was considerable push back from the public with nearly 100 public comments. The Commission voted to table the decision until their recent session that took place on Oct. 1st.

Under Title VI of the 1964 civil rights law, there are specific protections afforded to transit riders to protect against discriminatory practices and policies.  Our concerns are specific to the lack of a disparate impact analysis – a policy or practice that appears to be neutral but in fact has disproportionate affect on minority bus riders that lacks justification (such as moving a transit center without a public hearing) when an alternative can be considered in a public hearing. Also, a service equity impact analysis was not completed that considers access to work, social services, and essential destinations (doctor’s office, grocery store), in addition to ensuring that minority bus riders are not excluded from accessing destinations and municipalities based on their race. The Transit Justice Team raised the following concerns:

  • Title VI analyses have not been conducted and bus rider’s rights ignored
    • DDOT asserted they did not need to conduct analyses on potential adverse effects because the project did not receive federal dollars – FTA Title VI regulations and required analyses apply to all transit providers regardless if the project has local or federal funding.
    • No disparate impact analysis was conducted regarding adverse impacts on majority African American bus riders in terms of relocation of the State Fairgrounds Transit Center – it is concerning that a transit center can be moved without considering how this will adversely impact 30,000 DDOT riders that are majority Black/African-American and low income. If a transit center can be relocated without public input, considering that Detroit is majority African American, this will create a precedent that the City of Detroit does not have to consider race in terms of service and impact analyses for major transit-related development projects.
    • No service equity impact analysis was conducted on:
      • the relocation of a transit center and whether the relocation of six (6) DDOT routes either increase or potentially threaten access to Meijer, restaurants, shops, and other places of employment?
      • Impact on the rerouting of six (6) DDOT bus routes, changes to bus stop locations, headway (time between two scheduled buses), and impact on bus schedules.
    • Possible adverse impact analysis on para-transit riders were not made public, given that paratransit riders must live within 1 ½ mile of a fixed-route bus line to receive paratransit service. How will the relocation of DDOT routes affect an essential rider’s ability to use paratransit service if their route is moved away from their residential neighborhood?


  • Lack of transparency in the planning process
    • DDOT did not hold a public hearing
    • The three “community meetings” held by District 2 manager, Kim Tandy were nowhere sufficient in gaining public input and recommendations from bus riders
    • Information was presented about the transit center and bus re-routing only to attendees of the City meetings and bus riders have yet to see any route plan, bus stop placement, and there’s no date yet announced for a DDOT public hearing despite our demands to call for a date and hearing.
    • Members of the disability community received NO notice and their concerns were completely ignored or dismissed
    • ADA community were not seen as essential bus riders due to a narrative that seniors/disabled individuals/and people living with chronic illness only use paratransit – despite that it can take up to a month for approval. The community has concerns about adequate seating, charging outlets available for scooters/wheelchairs, shelters, and barrier-free access to bus stops and the physical distance from the commerce area to the transit center can impose hardship on riders from the ADA community.
    • Bus riders were only given a rendering of the transit center, will bus riders be forced to sit outside? What is the square footage of the new facility? Why don’t we have an actual blueprint? $7 million does not seem sufficient of an investment for a transit center that will be placed on land up to 7 acres as defined by the Purchase Agreement.
    • Ideas were given to reconstruct the Hertel Coliseum and other historical buildings were suggested for the new transit center but there isn’t any posted blueprint or building plans available to the public.


  • Lack of Environmental Analysis and Long-Term Negative Impacts on bus riders
    • long-term negative health impacts that truck and car emissions will have on majority Black/African-American and low-income bus riders, some with existing conditions that could be exacerbated by this development and could result in poor long-term health outcomes for essential bus riders.
    • Quality of life concerns: longer distance for seniors, and disabled bus riders to access the proposed transit center.


  • Racism in Transit Policy and Transit Center Relocation
    • A transit center should serve the needs of essential riders, not serve as a drop point for Amazon akin to apartheid transit routes in the former Apartheid South Africa that transported workers from townships to gold mines, this relocation of the transit center emphasizes transit as a private shuttle service for the private benefit of Amazon and Hillwood/Sterling Group instead of providing public transportation for common benefit of all bus riders, not just a service to shuttle workers.
    • Concerns raised that bus riders will be subject to excessive policing, surveillance, and harassment by Amazon security.
    • It seems the city is more concerned about the bottom line than the impact on their decision will have on majority Black/African American and low income essential riders and residents that will face several hardships related to rerouting, and relocating the transit center WITHOUT any public hearing or notice.
    • White developers received more information than majority Black Detroit essential bus riders and residents affected by this development.


Now that the City Planning Commission voted to recommend amendments to the Master Plan, the City Council is now the last elected body that will vote to approve the rezoning of the area, amendments to the master plan, and approval of the purchase agreement. Also, there is a provision to provide shuttle service for Amazon in lieu of timely construction of the new transit center. This is evidence alone that the transit center is for the sole purpose of transporting Amazon workers at our collective expense for their private benefit.

“In the event the Tenant Facility opens for business and the replacement Transit Center is not yet operational then the City will cooperate with the Tenant to provide interim transit capacity as necessary to

support the ongoing operations of the Tenant Facility.” – Purchase Agreement between the City of Detroit and Sterling Group/Hillwood (the developers).