September 14, 2020

Mikel Oglesby, Executive Director of Transit
Detroit Department of Transportation
1301 E. Warren
Detroit, MI 48207

RE: Inquiry regarding Federal Transit Administration analysis pertaining to the relocation of the State Fairgrounds Transit Center

Director Oglesby,

My name is Renard Monczunski and  I am writing to you on behalf of the Detroit People’s Platform Transit Justice Team. We organize across the city with over 500 DDOT essential bus riders to promote a safe, affordable and high performing public transit system for low income Detroiters.  The purpose of this letter is to bring to your attention several concerns related to the planned relocation of the current State Fairgrounds transit center as detailed in the purchase agreement between the City of Detroit and the Hillwood/Sterling Development Group.  This development site is intended to also include an Amazon warehouse distribution center as well.

Director, I’m writing to inquire as to whether this transit project qualifies for consideration and action steps as outlined in the Federal Transit Administration’s Title VI policy and directives for all FTA program recipients, namely programs 5307 and 5310, of which DDOT is a recipient. The relocation of bus service as identified in the current development planning discussions, has the potential to affect 30,000 bus riders weekly ­– a ridership that is predominately low-income and Black/African American.  As a result, one of our primary questions is whether  DDOT has completed a disparate impact and service equity impact analyses and  potential adverse effects associated with the relocation of six (6) DDOT routes. Also, what if any consideration has been given to possible adverse impacts on accessibility of senior citizens that rely on federally funded paratransit programs that serve that area?

Given the scale of this project, has DDOT conducted an independent and official public hearing to notify the community about the design, location, and plan to incorporate universal accessible design at the newly constructed transit center?

Equally important, has the department conducted specific or relevant independent health impact assessments and environmental impact analyses related to vehicle, bus, and truck emissions of which there is likely to be significant exposure by bus riders at the new transit site post construction. The impacts on a majority low-income and Black/African American ridership could elevate risk for illness resulting in cumulative and long-term poor health outcomes.

We believe as essential bus riders that DDOT, a public transit provider, has an independent obligation to safeguard the health and safety of its ridership. During recent public comments it is our opinion as an organized transit service constituency that these concerns have not been sufficiently vetted.

Given the timeline announced for this project, your timely response to these concerns is greatly appreciated.

Sincerely,
Renard L. Monczunski
Detroit People’s Platform – Transit Justice Organizer