Today, we submitted this letter via email to the University Staff from our sustainability committee. There are many unanswered questions around how the proposed bus yard will meet Federal regulations and the sustainability goals of the University.
Please see below and if you have any expertise in this area and would like to surface any additional concerns, please email us at: firstname.lastname@example.org.
Sent via Email on 5/20/16
with cc to President Schlissel Regents, Mayor and City Council Members
Good afternoon Jim, Hank and Sue,
We are hoping you can help provide answers to some important lingering questions regarding how the proposed facility will meet Federal regulations as well as the sustainability goals of the UM.
Based on the updated content on the Project website, the UM states that this project will have a “sustainable design that minimizes wetland impacts, manages storm water, meeting national and local design standards” and be “part of U-M’s desire to decrease carbon intensity of passenger trips on U-M transportation options by 30%.”
To support and justify these statements, can the UM Architecture, Engineering and Construction (AEC) staff provide the residents of Northeast Ann Arbor with answers to the following unresolved questions and issues (which have been raised previously):
1) Compliance with Federal Clean Water Act: One of the key regulations affecting development at this site is the presence of multiple wetlands. This undeveloped parcel currently contains six regulated wetlands (per ECT report and UM permit). Eliminating these wetlands by filling them and/or by partially filling them seems to violate the intent of Section 404 of the Clean Water Act – “The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (a) a practicable alternative exists that is less damaging to the aquatic environment” (USEPA website). The UM considered only one other location in its permit request and did not adequately weigh the pros and cons of these two sites. The UM needs to provide more information about how this site selection “meets national….standards.” The Clean Water Act requires that new projects that will impact existing wetlands have considered all viable options. The UM AEC Department has yet to demonstrate this that would satisfy the intent of the Clean Water Act and has not adequately demonstrated that other sites or even existing facilities (e.g., NCRC underutilized spaces) were adequately considered.
2) LEED Certification of Buildings: A stated goal of the UM Sustainability Initiative is to focus on “maximizing energy efficiency as well as incorporating other sustainability measures.”A highlight of this effort is to have development plans that include LEED certification of buildings. We have been told that one of the buildings on this location will be LEED Silver certified. Yet one of the criterion for LEED certification relates to site considerations that impact wetlands. Specifically, the U.S. Green Building Council states in its LEED ND Plan v.4 the requirement to “limit development effects on wetlands, water bodies, and surrounding buffer land” according to specific guidelines for reducing impacts on wetlands. Given the UM’s efforts on sustainability, how will the site location impact the university’s efforts to promote LEED certification of its buildings? Perhaps more importantly, how can any sustainable plan involve filling in and otherwise damaging and degrading quality wetlands? There are many recent reports that recognize the importance of wetlands (Ramsar 2010), acknowledge the continued demise and loss of these habitats (MDEQ 2014) , and advocate for sustainable development that avoids these impacts (USGBC). Given this, it seems that any building or facility that meets sustainable development guidelines needs to first, and foremost, consider the impacts to quality wetlands located on the site.
3) Impact of Articulated Buses: As part of the new proposed facility, the UM states that it plans to replace (or augment) its current fleet with 120 articulated buses. This is in response to the short-term need to increase passenger capacity since “articulated buses will meet ridership demand until the Connector come online.” Yet the UM AEC Department has not provided a detailed analysis of how this will help the University achieve its 30% decrease in carbon intensity of passenger trips. For example, El-Geneidy and Vijayakumar (2011) found that although articulated buses “yielded savings in dwell time” these savings were “offset by the loss in acceleration, deceleration and time consumed to merge back in the regular traffic.”
4) Alternatives to Achieve 30% decrease in carbon intensity of passenger trips: Right now, one of the main justifications in relocating this facility to this new site is to reduce gas costs and carbon emissions. There are two important issues related to this statement:
- UM Transportation is a very small part of the FY2012 UM Greenhouse emissions equaling just 1.1% of all the UM Greenhouse Gases in FY2012. UM Buildings were 44.8% of these emissions and Purchased Electricity was 54.1% of these emissions (see Figure 1 from M Planet website).
- Other options for reducing carbon intensity of passenger trips: The UM AEC has not demonstrated whether it has done a thorough analysis of other options for achieving this same reduction. For example, the UM currently houses several buses at it Parking Transportation Facility on Baxter Road. Has the UM considered a hybrid option whereby it houses some of its buses at different locations to reduce the distance the buses have to travel to being their routes? Why can’t the UM continue to house some buses at this Baxter Road lot as well at its Kipke St. lot? Could the UM also house some buses at it Glazier Way commuter lot, since this would dramatically reduce transit from any outside location? Also, several studies have looked at ways to reduce emissions of buses just by varying “transit signal priority,” bus stop location, and idling operations. Has the UM explored ways to reduce emissions just by using state-of-the-art approaches to managing operations? If so, what were the findings of these studies?
Thank you for your time and consideration. We look forward to our meeting on Tuesday.
Northeast Ann Arbor Community Coalition
Figure 1. Estimated FY 2012 Greenhouse Gas Emissions for the University of Michigan.
 El-Geneidy, A. M., & Vijayakumar, N. (2011). The effects of articulated buses on dwell and running times. Journal of Public Transportation, 14(3), 4.