COMMENTS: Union Station SDEIS (Support)

July 5, 2023

Amanda Murphy
Deputy Federal Preservation Officer 
Office of Federal Railroad Policy and Development
USDOT Federal Railroad Administration (MS-20)
1200 New Jersey Avenue, SE
Washington, DC 20590

Re: Comment on the Washington Union Station Supplemental Draft Environmental Impact Statement

Dear Ms. Murphy:

The Coalition for Smarter Growth is a 26-year-old non-profit and our mission is to advocate for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. The expansion and redesign of Union Station represents one of the most important land use and transportation decision in the DC region in recent memory and is a 100-year decision that we must get right.

Our shared vision must be bold, it must put rail and bus transit, biking, and walking first, and it should turn Union Station into a truly transit-oriented center at the heart of our city. For this reason, we could not support the proposed project outlined in the FRA’s Draft EIS (DEIS) Preferred Alternatives A-C in 2020. Since then, the FRA, USRC, and Amtrak have revised the project design to address the concerns we and others raised in 2020. Thank you.

Today, the new project vision defined in the FRA’s Supplemental Draft EIS (SDEIS) Preferred Alternative F presents a bold vision for the next century of Union Station’s existence and success, and will gain broad public and political support. The revised SDEIS Preferred Alternative includes major improvements we support the FRA including in the Final EIS:

  • Right-sized parking located below-grade:
    We applaud the FRA for reducing the station’s reliance on automobiles in the SDEIS by lowering the maximum parking spaces from 1,600 to 550-400 parking spaces. The creation of a centralized below-grade vehicle facility will more effectively support parking, pick-up and drop-off, and rental car demand.
  • Modernized and efficient PUDO (Pick-Up and Drop-Off):
    The centralized PUDO area prioritizes pedestrians and cyclists and maximizes the efficiency of Transportation Network Companies (TNCs) by reducing idling and vehicle miles traveled (VMT) to and from the station. The SDEIS Preferred Alternative F creates new access points to the station with the creation of below-grade PUDO facilities, reduces congestion in and around Columbus Circle, and increases access to station platforms from PUDO areas for customers.  
  • Bus facility better integrated with minimized impacts to the street network:
    The bus facility presented in the SDEIS will enhance multimodal access, and civic and economic opportunities for Union Station and the District. The new design will significantly improve the passenger experience for the projected 3 million intercity bus riders traveling through Union Station annually by 2040. We appreciate the FRA’s designation of 38-39 bus slips, 15 additional bus slips for high-capacity events, and the central location of the bus facility in the SDEIS Preferred Alt. F. We fully support maintaining this facility’s size and location in the Final EIS.   
  • Improved bicycle facilities:
    We applaud the FRA for incorporating bicycle access, bicycle and bike share parking, and programming as important components of the SDEIS Preferred Alternative. We also believe that the SDEIS’s proposed plans for parking, PUDO, and the bus facility mitigate unsafe interactions between vehicles and vulnerable road users. We commend the FRA for addressing safety concerns regarding bike lanes and pedestrian zones throughout the construction.
  • Beautiful, fully- integrated urban design: 
    The station elements of the SDEIS Preferred Alternative F create a truly world-class multimodal transportation facility. The SDEIS incorporates design elements that support the iconic entry to the station from the north, and open spaces that will serve the public and benefit the neighborhoods that surround the station. By eliminating the above-grade parking facility, the SDEIS enables the development of a vibrant urban environment for both residents and visitors, and ties back together the neighborhoods on the two sides of the station. By making possible significant air rights development the design will help maximize transit ridership and support activities that tie the legal and regulatory center of our nation with our financial center of New York City and all of the other economic hubs along the Northeast and Southeast Corridors.

We strongly support these changes to the SDEIS Preferred Alternative F, and we encourage the FRA to include these important improvements and project elements in the Final EIS. However, some elements of the project remain insufficiently analyzed or not addressed in the SDEIS. We call on the FRA to address the following in the Final EIS to ensure the project’s success:

  • Include run-through service for Virginia Railway Express (VRE):
    The SDEIS identifies future service “from” MARC’s Penn Line “to” VRE’s Fredericksburg and Manassas’ lines, but should also explicitly include connecting run-through service for VRE. Providing a one-seat ride from Virginia into Maryland via VRE will further interconnect the region’s economy and greatly enhance the quality of life of Virginia’s commuters along the I-95 and I-66 corridors.
  • Unify the federal and public air rights to ensure full delivery of public benefits: 
    Successfully achieving air rights development is critical to maximizing rail and transit ridership, knitting the city back together in the area north of the station, creating a vibrant and dynamic community, enhancing the value of the station, and expanding the city’s tax base. However, the SDEIS Preferred Alternative F lacks critical definition of responsibility and coordination between the private air rights developer Akridge, and the FRA-owned federal air rights development parcel, as specified in the SDEIS. This ambiguity and lack of ownership of the FRA’s role in funding and coordinating the deck to support federal and air rights development raise questions about the overall viability of any development and significantly reduces the overall benefits that could be delivered by the SEP. Despite the promise of best-in-class urban design in the SDEIS’s images and renderings of Preferred Alternative F, the FRA does not fully articulate or acknowledge the federal government’s role in facilitating, funding, and coordinating air rights development. Specifically, it remains unclear what specific measures the FRA is undertaking to overcome the obstacles posed by the fragmented federal and private air rights, which could hinder the area’s development. 

    We also believe that the Final EIS should revise the No-Action Alternative. The current No-Action Alternative includes the development of private air rights but fails to consider the irreversible negative consequences of pursuing this development independently from the SEP. If the air rights development proceeds without the SEP, it will eliminate any opportunity to address the existing accessibility and safety concerns of the station or adequately meet the future rail capacity requirements, possibly rendering these issues unsolvable indefinitely.
  • Clarify and solidify USRC’s role as Project Sponsor for effective delivery of the SEP: 
    We applaud the FRA for designating USRC as the Project Sponsor of the SEP in the SDEIS. An empowered and well-resourced USRC will ensure there is a single point of authority for taking the SEP through the design and construction of this mega-project. However, to ensure USRC’s success in this role, we encourage the FRA to define the Project Area authority that USRC will oversee for the design and construction and to identify the authorities and resources that the FRA and Amtrak will provide to support the effective delivery of the SEP. We believe that the FRA must take these steps to ensure that USRC has the necessary staffing and financial resources to implement the project expeditiously. 

    Additionally, the SDEIS highlights the need for regional investment in the SEP as a result of the reduced parking revenue to sustain USRC’s operations. However, we believe that regardless of the implementation of the SEP, USRC is already unable to rely on parking revenues to sustain operations of the historic station. We encourage the FRA to broaden the rationale for USRC to identify new revenue sources for reasons beyond the loss of parking revenue, and the need for regional investment due to the benefits of expanded rail and bus service facilitated by the SEP.  

Once again, we thank the FRA for the work to make the changes in the SDEIS. We hope that the FRA will continue to expedite completion of the environmental review process by issuing a ROD for the SEP by January 2024. We also hope that the project’s anticipated timeline of 13 years can be streamlined and expedited to align with Virginia’s historic passenger rail investments in the Transforming Rail in Virginia program, and to address the urgent need to slash greenhouse gas emissions from transportation.

The Washington Union Station project must be a national and regional priority. It is essential for strengthening the rail connections for the Northeast and Southeast rail corridors, supports a unified commuter rail network in the Capital Region, and will provide significant economic, transportation, and job creation benefits for the region. We look forward to the transformation of our Nation’s Station into the vibrant multimodal hub we need for the next century. 

Stewart Schwartz