Streetcar MKE Streetcar: Personal Blog

Comment on the Milwaukee North-South Transit Enhancement Study

"Milwaukee County and the Southeastern Wisconsin Regional Planning Commission (SEWRPC) are beginning a transit study along and near 27th Street to enhance transit service, increase frequency, add amenities, and potentially expand the existing Milwaukee County Transit Service (MCTS) PurpleLine service area. Both rail and bus services will be evaluated. These transit improvements are expected to increase transit ridership along the corridor and will serve those residents and businesses along the preferred alternative." MKENorthSouth.com, March 2021

by John December / Updates/More Info: johndecember.com/mke Bookmark and Share

This is my comment on this plan that I sent in via their public engagement process.

11:10 AM 2021-03-30

Thank you for your work on The Milwaukee North-South Transit Enhancement project and for accepting this public comment. This project presents an opportunity to remove barriers for underserved residents, address equity concerns, and strengthen our economy by providing quality transit.

As a Milwaukee County resident, transit rider, and car-free household, I rely on public transportation and walking to get around. I live in Milwaukee's lower east side, and I've traveled to 27th Street by bus for shopping and medical appointments. I'd like to offer my insights to help fill in some specifics of what a car-free person experiences. Also, I can shed some light on the transit modes of your study, as I use The Hop streetcar for transit and have a good idea of its use in comparison with bus transportation. It is a privilege for me to use transit, and I hope that my comments can enhance transit for the entire community.

My main point is this: to enhance transit along the 27th Street corridor, we must first identify biases and inequities that affect planning decisions and make a commitment to rectify them. Then, I believe we can enhance transit with 1) quality transit experiences, 2) rider and community-supportive infrastructure, and 3) connected destinations. Our vision can be a community where all people, using many different transit modes, may fully participate in our civic life. I conclude by identifying a streetcar as a mode choice for this project that can meet the need to build equity and enhance transit.

The requirement to identify, acknowledge, and rectify inequities is clear. Milwaukee County Ordinance No. 20-4 requires a commitment to identify racial equity impacts (Milwaukee County, 2020). Federal Executive Order 13985 states "..each agency must assess whether, and to what extent, its programs and policies perpetuate systemic barriers to opportunities and benefits for people of color and other underserved groups" who have been "systematically denied a full opportunity to participate in aspects of economic, social, and civic life..." (Biden, 2021). Compliance is required with the Americans with Disabilities Act (ADA National Network) and Title VI of the Civil Rights Act of 1964 (Federal Transit Administration).

The infrastructure and land use surrounding transit likewise must be free from structural racism (Short, 2019; Thomas, 2020; Spieler, 2020). The damage to Milwaukee communities already done through historic devastation wrought by highway construction and segregation (Ware, 2021; Niemuth, 2014; Orum, 1995) must be recognized and rebalanced by spending on other transit modes to compensate. Along the 27th Street corridor, residents have low incomes and rely on public transportation (28% are in poverty and 23% have no access to a vehicle). Others may wish to use transit but do not. The project should work with climate goals (State of Wisconsin, "The Governor's Task Force on Climate Change Report," 2020) and reduce automobile dependency to make the most productive use of limited urban land for economic benefits and jobs (Newman and Kenworthy, 1999; Fitzgerald 2020). Considering these requirements to address equity concerns, this project needs to first recognize that the passage of persons in Milwaukee County should not be constrained by transportation or barriers that do not serve their need to participate in economic, social, and civic life.

Addressing inequities requires that we identify the biases and underlying assumptions affecting transit:

1) Bias happens when decisions are made entirely by people who are car-dependent and who view the world in terms of automobile-centric values and needs.

2) Bias is portraying or implying the use of transit as somehow reflecting a deficiency in the individual, which is deeply disrespectful.

3) Bias is not considering the total transit experience including navigating to and from transit stops and the experience of boarding, riding, and alighting from the transit vehicle.

4) Bias is separating transit from a community context and ignoring land use issues that prevent or impede the use of transit.

5) Bias involves providing no dedicated funding sources for transit when other public infrastructure categories have dedicated funding.

6) Bias happens, as described by planner Destiny Thomas, through a "planning process by which certain neighborhoods (and certain people) are deemed expendable due to their racial, cultural, or economic location on the spectrum of socio-economic privilege... as a result of a structural and collective effort to control the means to mobility and movement" (Thomas, "#PurpleLining," 2020).

7) Bias is a decision process where scalar variables such as vehicle speed and cost are viewed as ultimate, using this as a deterministic justification to ignore the quality of the transit experience, the environment, and long-term community needs and benefits.

8) Bias arises from the role of racism and classism in the reaction to pedestrian deaths and safety concerns (Schmitt, 2020).

9) Bias happens when design assumptions place automobile use as dominant, with dedicated, permanent infrastructure, while walking and transit use is seen as inferior with ephemeral support and little permanent infrastructure.

To rectify these inequities and biases and serve the underserved, we need to first pay attention to the total transit experience. An article in Hopkins Bloomberg Public Health magazine reports that "unreliable mass transit, transportation costs, and unequal access have contributed to longstanding structural racism and associated socioeconomic barriers that have segregated communities" (Powder, 2020). The article goes on to describe how unreliable transit and costs lead to unequal access to jobs, food, healthcare, education, and other services and destinations.

As a car-free household, I know what it means to rely on transit. Daily tasks for necessities such as accessing employment, school, groceries, pharmacy, healthcare, and recreation may involve planning and travel involving multiple transit modes or transfers. These strategies are often thwarted by policies that place automobile travel as a privileged mode, literally blocking out and endangering persons engaged in other modes of travel. Fumes of vehicle fuel enter the air that a person has to breathe. Total U.S. greenhouse gas emissions by transportation are 28% of the total, and "90 percent of the fuel used for transportation is petroleum-based, which includes primarily gasoline and diesel" (United States Environmental Protection Agency, "Sources of Greenhouse Gas Emissions"). The noise of buses can be quite loud. The 27th Street corridor has been called the "Deadliest road in Milwaukee" (Klopf, 2021) because of its danger to pedestrians. The experience of pedestrians is often ignored and made more difficult due to bias in engineering, unresponsive infrastructure, and lack of attention to safety concerns for pedestrians (Schmitt, 2020). The disabled and elderly also suffer through difficult experiences. All this reflects transit that is not in balance.

Structural inequities seem to arise when planners don't look at the experience of the entire transit trip within the urban landscape. A trip involves not just getting "from A to B," but starting from one's origin, traveling to a transit stop, the experience boarding, the experience on the vehicle, the experience alighting, the experience of possible mode transfers, and a trip from the transit vehicle to the destination and entrance to a store, office, school, or job site. The phrase "from A to B" implies that only the curb-touching points of the trip are what matters. This removes the total experience of the rider to one that emphasizes a single variable, such as speed or cost. For car drivers, "from A to B" may involve a step into their garage, a drive, and a walk from the car into a building. The automobile trip enjoys government subsidies by specific policies such as a too-low gas tax that doesn't cover the cost of automobile travel and road construction (Dutzik et al., 2015). The automobile trip is also supported by public policies that place free parking as an ideal, while it has shown to be a burden on the poor and non-drivers (Shoup, 2011; Shoup, 2018).

From the perspective of an automobile driver, "from A to B" is the perfect phrase to reduce transit to a service to be minimized through systemic inequities without regard to the community or environment. Land use policies emphasize the automobile experience, allowing decisions to block the creation of affordable housing, thwart placing affordable housing near transit, provide oversupplies of free parking, and remove anything but "from A to B" from decisions about transit. If rider experience, community cost, or environmental factors are dismissed entirely or assumed to be zero, inequities in transit inevitably result.

For a car-free household of limited income, choices in the urban environment for affordable housing near high-quality transit are limited. The goal of someone in this situation is to manage not just the transit costs but the housing + transit + transit experience costs. The distribution of low-density housing among low-density development immediately adds to the transportation burden because bus service to low-density developments will have longer service intervals, longer travel times, and involve walking to and from street intersections and roadside areas that have been optimized for automobile flow--with massive road widths, poorly marked or malfunctioning crosswalks, and extremely fast automobile traffic. This landscape is "Dangerous by Design" (Smart Growth America 2020) and adds to what I term "transit experience costs" because they wear on (or may kill) an individual. This experience cost is further increased by the impermanence of bus service--where routes can be canceled, removed, or moved. A transit rider may have been depending on a route for proximity to current housing, job, and shopping destinations. This destabilizes the living situation and reduces trust in public transit because no commitment is made to the transit rider.

An "A to B" planning analysis that erases the total experience of riders skews decisions a person might have to make. A household may feel the need to have no less than one car per adult in order to live in a pedestrian-hostile landscape. There may be no car-free housing available where parking space construction is removed from the design of a residential building site placed near a transit stop to make the per-unit rental costs lower. The assumption bias embedded in the planning process is that parking is either not enough or it is satisfactory--there may be no way to express the view that the amount of parking is excessive. A renter may have no car but have rent increased by "bundled parking" that the renter doesn't use or need (The Center for Neighborhood Technology, 2016). A family might save over $9,000 annually by getting rid of a car if they could reliably meet their needs with transit (Bureau of Transportation Statistics, 2019). Families who own several cars may be able to lift themselves out of poverty by getting rid of one or more cars if they are well-served by transit.

My experience traveling to 27th Street via Milwaukee County Transit Service bus for shopping and medical appointments at Aurora St Luke's informs my observations about the car-dominated landscape. I discontinued my attendance at cardiac rehab at Aurora St. Luke's because of the discomfort of traveling by bus and the complex and stressful nature of navigating to the hospital. Aurora St Luke's has a transit score of just 50 (out of 100) and a walk score of 52 (out of 100) (Walkscore, 2021) despite it being such a major employment and healthcare destination. I also stopped shopping in the corridor for the same reason. It may be easier for me to order online, but local businesses of all kinds suffer because of the lack of local patronage. On my shopping trips, I would have a meal in a restaurant along 27th Street and shop at a variety of local stores. As of now, due to the pandemic, I've limited my travel to my local neighborhood, using walking and The Hop streetcar. I find the features of the streetcar help me make easier connections and significantly helped me during a period when I used a walker as an assistive device after heart surgery. It was very easy to step on and off the streetcar and gain a seat, on level flooring, in the center section area (see my blog entry listed in the Reference section, "Year of The Hop").

We can enhance transit with rider-focused and community-supportive infrastructure. The bias to overcome is that the existing infrastructure fails to meet the needs of communities isolated from transit through land-use decisions that favor automobiles and place destinations far apart. There is an elaborate and growing system of permanent infrastructure optimized to service the movement and storage of automobiles, yet the infrastructure for walking and transit is seen as ephemeral. Parking requirements push neighborhood-serving grocery stores or pharmacies out of reach (Shoup, 2018). Bus routes that can be canceled or moved at a whim. Excessive widths of the streets and turn lanes relentlessly endanger pedestrians. Massive free parking lots disrupt mobility for walkers and spread out destinations adding to the walking and transit burdens.

There is a need to remove the infrastructure design bias. The requirements for highway standards on the corridor overpower all other concerns. A better emphasis would be standards for a community-serving boulevard. I acknowledge that this may not be possible, but I identify it as a design bias that this project needs to mitigate. Public transit infrastructure is community-supporting and offers numerous benefits and economic returns (American Public Transportation Association, 2021). However, public transit needs permanent funding, permanent infrastructure, a permanent effort for design and planning, and a permanent commitment to people who use it. Creating Milwaukee County transit as only a "drive-thru" service emphasizing road access while sending jobs and workers to locations outside the county is not an equitable policy, nor does it serve the economy of our county.

We can enhance transit by creating destinations and connections to them for walking to counter the overall design bias in favor of the car-oriented distribution of destinations. Researcher Donald Shoup eloquently summarized the benefits of shifting this emphasis: "We can achieve enormous social, economic, and environmental benefits at almost no cost simply by subsidizing people and places, not parking and cars" (Shoup, 2011). Boulevard standards can offer benefits over highway standards (Crowther, 2021). Examples and patterns from throughout the world show how urban land can be more productively used and provide access for people using all transit modes (Newman and Kenworthy, 1999).

The idea of connected destinations relates to the concept of urban fabrics that researchers have identified. The three fabrics of urbanism are defined as walking, transit, and automobile, with the automobile city being a mix of these three fabrics (Newman and Kenworthy, 1999). These fabrics "need to have different approaches" for planning, and the emphasis on the automobile fabric is "...a major contributor to the growth of automobile dependence in both the creation of new auto fabric on the urban fringe and the deterioration of walking and transit fabric due to the imposition of automobile fabric such as parking, road widening, and large setbacks." (Newman, Kosonen, and Kenworthy, 2016). These researchers point out that planners "will need different strategic and statutory manuals for built form typologies that fit the different urban fabrics. Without this, the dominant automobile city framework will still be used despite the economic, environmental, and social demand for more walking and transit fabric" (Newman, Kosonen, and Kenworthy, 2016).

In this case of the 27th Street corridor, a balance can be made among the needs of these three urban fabrics. The infrastructure for walking and transit must be emphasized to compensate for overwhelming automobile emphasis. The permanent commitment to fixed infrastructure is the rationale behind the highway and street system from Roman times to the present (Reader, 2004; Marshall, 2000). The same commitment to permanence must be given to walking and transit so these fabrics can reach greater equity, and literally "hold their ground" in the face of automobile emphasis.

Of the modes this project considers, the streetcar represents an opportunity to bring high-quality transit, proven for years locally on our streets and climate in Milwaukee, and addresses the needs for equity, user experience, permanent transit infrastructure, and connected destinations. A streetcar brings emissions-free vehicles which offer a user-oriented design, rapid boarding and alighting, and ADA-compliant level-boarding areas. The serious consideration of a streetcar should be a viable option for this project and not be rejected outright because of higher initial construction costs, misconceptions about its operation, intra-agency rivalry, or politically-motivated opposition (Spieler, 2018, p. 13; Mayer, 2017; Litman, "Rail Transit In America," 2020).

I advocate for the choice of a streetcar based on my experience of using The Hop in Milwaukee since it opened in 2018. I have documented my experience (December, "Year of The Hop," 2021) and the advantages of streetcars (December, "Advantages of Streetcars," 2021). A streetcar can provide the kind of high-quality transit that is seen as lacking for underserved communities (Spieler, 2020; Spieler, 2018).

The discussions about a streetcar as a transit mode involve a considerable amount of misconceptions and false dichotomies. Assertions that a streetcar could only be used by one ridership group--such as tourists or elites--and not residents--are false, as I can see by my own experience and use of the streetcar. I document the many, diverse destinations for The Hop's route (December, "MKE Streetcar 'The Hop' Destination Guide," 2021) and the hundreds of streetcar systems throughout the world show a variety of riders. Assertions that streetcars are primarily or only for development (King and Fischer, 2016) and not transit are likewise false dichotomies because streetcars can serve both needs. Other discussions about the streetcar spread false fears (such as bikes or motorcycles not co-existing with the tracks or that the streetcar wouldn't run in snow) that have been disproven. I've come to see certain repeated statements reflect a common set of tropes. These types of statements might be politically motivated or influenced (Mayer, 2017; Spieler, 2018, p. 13). It is important that this project identify the motivation behind statements about the streetcar and be cautious of statements from people who have never used it regularly, are commenting from outside the area, or have a political motivation to prevent transit or streetcars from being used.

Researchers have examined development activity along streetcar routes. Mendez and Brown (2019) studied Portland and Seattle and found that "in certain contexts streetcars are associated with increased development activity." These researchers caution that the function of the streetcar system as transportation is key: "the more effective a streetcar is as a transportation service, and the more widely used it is by patrons, the more likely it is to have development effects" (Brown and Mendez, 2018). Ramos-Santiago, Brown, and Nixon (2016) examined the role of streetcars for transportation as well as for development and pointed out both functions--transportation and development--are being pursued. New buildings have been and are being constructed along The Hop's Main Line in Milwaukee since its opening (December, "Advantages of Streetcars," 2021). I know of no research showing bus transit motivates development, and this may be due to its impermanence as infrastructure.

With development along a streetcar route and observations of higher land values, there are concerns about gentrification and displacement (Diciaula, 2019). Anti-displacement-oriented planning should work toward equity by "community connectivity and neighborhood network planning" (Thomas, 2020). Isolating populations from high-quality transit by placing rail transit in just one location likewise causes inequities due to scarcity when communities without rail transit are left behind or stranded (Spieler, 2018). The permanence of the streetcar does seem to motivate development, but a streetcar can be managed well to provide quality transportation (Li, 2008; Pitstick, 2018; Li et al., 2011; Nguyen, 2017; U.S. Department of Transportation, 2016). The concept of a transportation equity fund might be considered to provide a funding source to mitigate displacement and build affordable transit-proximate housing, a concept reported in recent developments along The Hop's Lakefront Line (Jannene, 2021). Attention toward equity along with neighborhood network planning may bring the positive results of increased jobs, housing, access, and walkability to communities along with high-quality transit.

This is a list of the advantages of The Hop and its modern streetcar service that I have compiled (for a complete list with citations, photos, and videos, see my blog entry "Streetcar Advantages" listed in the References section):

1. Emissions-free, quiet (but not silent) operation: People feel comfortable being close to the vehicles.

2. Accessibility through large doors: Two large double doors open at the stops allowing many people to board and alight quickly and conveniently, even if carrying bags or using an assistive device. These large doors also provide excellent ventilation.

3. ADA-compliant, level-loading: People can access the streetcar platform along a gently sloping ramp and board all on one level, without stairs. People using assistive devices board along with everyone at the same time.

4. ADA-compliant, level-floor seating area: The interior middle section of the streetcar allows wheelchairs to roll to a seating area that has fold-down seats for people who need to sit in the level-floor area.

5. A smooth ride: I've ridden buses for many decades of my life, and The Hop's movement on rails makes for a smoother ride than any bus I've ever ridden because the pitching, yawing, and rolling motions are dampened. Momentum due to starts and stops remains a caution (Newton's first law of motion).

6. System design connecting walksheds centered at stations: The stations are set along the route so that the streetcar connects passengers to walkable areas covering the entire corridor. (A walkshed is the area around the station that people can be expected to walk to or from the vehicle; a distance of about 400 meters is often used as this walkshed distance. (Massachusetts Bay Transportation Authority, 2016; PedShet.net)).

7. Low-resistance rail operation: The rolling resistance of the streetcar's wheels on rail is much less than rubber-tired vehicles on the pavement. This efficiency factor is estimated by different sources. The Steel Interstate Coalition estimates that rail reduces rolling friction by 85-99% versus rubber tires. The article "Why Rail Has 20X Energy Saving Advantage Over Rubber Tire Road Vehicles - The Science of Locomotion" also explains this efficiency. This fundamental fact of physics makes streetcars more energy-efficient to operate than a wheeled bus system. This energy advantage enables electric-powered rail transit vehicles to run in cold weather. The Hop demonstrated its ability in cold weather when running during polar vortex conditions. An electric bus, requiring more power, may never achieve this advantage. People who don't understand this efficiency don't appreciate how the tremendous rolling resistance efficiency of rail allows for electric operation with less power. This rail efficiency allows lower operational and life-cycle costs for the system's power over its lifetime.

8. Fixed rail infrastructure placement: The predictable-path travel of rail means that the streetcars can be placed closely within pedestrian-oriented areas. This may seem so "obvious" that it is widely discounted and the significance of it is not even understood. Quite simply, it means that streetcars fit exactly into areas where people are at markets, public squares, shopping areas, and outdoor plazas (such as at Fiserv Forum in Milwaukee) because people can see the tracks and know exactly where the vehicles are traveling.

9. Fixed rail infrastructure commitment: The fixed nature of the streetcar tracks connotes an investment in an area's infrastructure that captures attention for land use decisions. The streetcar tracks signal a long-term commitment that a developer nearby can rely on. Residents also can rely on this commitment for choosing housing or employment.

10. The ability to support development: The Hop supports new housing, offices, jobs, and businesses by bringing passengers near to their front doors. These newly built or existing destinations then generate passenger trips that the streetcar can fulfill. This is the fundamental dynamic of the streetcar as a catalyst for growth--the positive, mutual support of development and transit. Each of the components--development and streetcars--must each meet their goals well and be oriented to supporting and gaining from each other. This may have been the factor behind Portland's success, where development and streetcars were planned together (City of Portland Bureau of Transportation, "Portland Streetcar: Strategic Plan 2015-2020").

11. The ability to run in all weather: The Hop has run in snow, rain, snowstorms, cold (including the polar vortex when air temperature reached -28 C (-20 F) and wind chills -40 C (-40 F)), heat, and blizzards.

12. Hybrid battery and overhead-wire energy system: The Hop can draw power from the overhead wire through the pantograph or through onboard lithium-ion batteries. This allows for reduced construction costs and lengths of the route on which no overhead wires need to be constructed (Booth, 2019).

13. Record of safety: The Hop's record of safety during all of its operations has been exemplary.

14. Capacity: The Hop can accommodate a total of 103 passengers: 30 on fixed seats, 4 on flip-up seats, and 69 standees, according to the Brookville Equipment Corporation (Brookville, 2021). There are also seats for operators in each enclosed end cabin. Informal observations during Bastille Days has shown this capability with standees also using floorspace in the end seating sections and holding on to the overhead straps, giving a bit more capacity. This flexibility allows The Hop to serve many people during peak-demand periods.

15. Operator cabin secure: The operator of The Hop is in a locked cabin, with video and audio contact with the interior of the streetcar; this improves the safety of operation of the vehicle as well as removes the choke-point on buses where the driver is at the entrance of the bus, causing considerable delays as passengers board and pay their fares, stand, or chit-chat with the bus driver while the bus is in operation.

16. Well-designed interior: The layout and seating areas are distinct, with the two end sections offering seating facing toward each end of the streetcar (that is, forward in the direction of travel in the front, and backward to the direction of travel in the back (just to note: I find it completely satisfactory to ride facing either direction)). The middle section offers level-floor seating and room for standees. The result is a flexible layout that allows for larger passenger loads or social distancing. The volume of space is impressively greater than that of a bus, and the aisle distances and the ground-level area make it easier to get around. I like the same-direction seating on the end cabins. I like this interior layout better than any transit vehicle I've ever ridden.

17. Attention-getting service to diverse destinations: From The Hop's opening to the present, I see people look at and notice The Hop and, pre-covid, would make a point to ride it. This helps Milwaukee's tourism industry. The Hop was noted in an article by former Madison Mayor Dave Cieslewicz entitled "Civic envy: Milwaukee has eclipsed Madison in two big ways," with the two ways being food offerings and the streetcar (Cieslewicz, 2019). The Hop is also for residents: as a resident, I have used the streetcar for day-to-day needs, and I've observed others doing so, including stops for groceries, medical appointments, travel to restaurants, libraries, schools, historic sites, parks, and more.

18. Strength in supporting development, including affordable housing: Buildings can be placed right near the streetcar stop and allow for transit-oriented (Federal Transit Administration, "TOD Foundational Research") efforts, including affordable housing or even car-free housing.

19. The ability to draw and increase ridership for a transit route: A report (Tennyson, 1989) shows that the transit mode does matter in how people choose transit, with rail being favored. Gaining ridership is a major challenge for a transit agency, and having a mode that is shown to appeal to people can significantly help in this effort. The appeal of rail is an ongoing attraction and retention factor.

20. Support of walkable urbanism: The streetcar's nature as a connector of walksheds and its emissions-free, quiet operation makes it a perfect fit for areas that are oriented toward urban design patterns that place people first such as in New Urbanist concepts.

21. The ability to carry bicycles: People can make use of The Hop to move through the downtown without worrying about automobile traffic while at the same time transporting their bicycle. This allows The Hop to be an extender of bicycles used for transportation. Bublr bike stations are also near Hop stops.

22. Use as a walk extender: The streetcar can serve needs outside of its walkshed limits by using a streetcar trip as part of a longer trip involving walking. For example, I used The Hop to first travel to its St Paul at Plankinton stop, and then walk further down to a meeting at the Anodyne Walker's Point cafe. This use assumes the passenger will walk beyond the 400-meter walkshed limit, but I find my walking limit is further, and that the use of the streetcar as a starting segment of my journey greatly expands the walking area I can access.

23. Large windows: The big windows in the seating areas allow you to look out over the city as you ride, see businesses, and see the life of the city. This is tremendously important, and one of the major features I've enjoyed.

24. Permanence as infrastructure: The Hop motivates development because it is built as part of the city's public infrastructure. Other public infrastructure such as streets, sidewalks, bridges, utilities, sewage, and other systems make up the public offerings of the city and are the basis for attracting and retaining residents, private development, and supporting commerce, culture, and civic life. The streetcar's funding comes from the same recognition that a fixed infrastructure in one part of the city benefits the whole city as well as the region and even the state. The logical fallacy of opposing the streetcar because it is in fixed location contradicts spending on fixed location infrastructure of all kinds--from sewers to sidewalks, from bridges to airports, from city streets to parks of all kinds--each has a location, in a specific place. It is the fixed nature of this built infrastructure that is of benefit just as the fixed natural infrastructure, like the lake and rivers and land, is of benefit. The streetcar tracks define a fixed transportation route, just as streets, highways, and other transportation infrastructure, and this shapes the city (Marshall, 2000; Reader, 2004; Newman and Kenworthy, 1999).

25. The ability to alleviate the need for automobile storage at destinations: A good example is the Hop stop at The Milwaukee Public Market, where dozens of people at a time can be placed at its doorstep by The Hop. Those people don't have to drive or store a car nearby.

26. Reliability: I've seen the streetcar consistently perform on-time, and there is a set schedule for the streetcar to arrive at each stop. Delays have usually been caused by illegally-parked automobiles. Signal priority techniques (Li, 2008; Pitstick, 2018; Li et al., 2011) help the streetcar travel through intersections more quickly, creating a kind of "virtual right-of-way" that addresses many problems of not having a physical right-of-way.

27. Traffic calming and safer passage for pedestrians: The Hop's presence on the street seems to somewhat motivate drivers to obey traffic laws, obey parking laws, and generally slow down and observe their surroundings while passengers on The Hop are protected on their ride from these drivers.

28. Curb space benefits: The streetcar utilizes the curb space for bringing people to and from destinations much more efficiently than an individual vehicle. The Hop vehicle itself takes up less space on the road than if its passengers were in individual vehicles. Curb space management is a key to the success of an urban area, as the dropoff and loading areas to major stores or attractions tend to be poorly managed--with either the space given away for free which encourages traffic congestion in a hunt for "free parking" or illegally-parked cars, illegally-idling Uber or Lyft vehicles, or illegally-parked delivery trucks. The mismanagement of curb space slows the productive use of urban land near activities that are enjoying particular success--curb space competition is a sign of good business. The streetcar offers a transportation mode that can help solve this through high-capacity passenger delivery to attractions. The streetcar thus opens up possibilities for modern parking reform (Shoup, 2018).

29. Appropriate speed: The Hop is a public transit vehicle so it makes stops to pick up and discharge passengers. The door design makes this very rapid. The progress of the vehicle along its route is appropriate for the speed limit of the streets, the safety of pedestrians, and matches similar bus service speeds. With signal priority (Li, 2008) and enforcement of parking laws along the route, The Hop's speed could be made higher. However, as a passenger, I find the speed perfectly adequate, and I don't consider speed the sole value of the streetcar, but I value the connectivity the streetcar gives to destinations, its reliability, and the quality of the ride. According to the Brookville Equipment Corporation, the maximum speed of the Liberty Modern streetcar is 48 mph (77 km/h) (Brookville, 2021).

30. Addressing climate change and meeting the challenge of the changing nature of cities: The Hop fits into Milwaukee's plans for addressing climate change and environmental issues (City of Milwaukee, "Environmental Collaboration Office (ECO)"). Powered by electricity, the streetcar is ready to use renewable sources. While electricity generation currently uses only a portion of renewable and sustainable energy sources, more can be developed.

31. Cost considerations: The perception that the high initial costs of streetcar construction alone removes it from consideration for urban transit seems to be a misguided one when considering maintenance, life cycle, energy, staffing, ridership attraction and retention, and land use costs and benefits. Streetcars ride smoothly on wheels in contact with rails and never touch the pavement of the street, unlike bus tires, and thus the vehicles and the pavement don't endure the damages resulting from bouncing of the vehicles. Streetcars have more capacity and enable a single operator to carry more passengers. Energy costs are much lower because of the physics of rail-travel efficiency. Streetcars also capture the attention of potential riders and provide a smoother, more satisfactory ride, and thus could lower ridership attraction and retention costs. The required ADA-compliant features of the streetcars are integrated into the design of vehicles, allowing level, equal-access boarding. The initial costs are high--construction of tracks--but the long-term operating and life-cycle costs may be less than expected. Further, savings due to air quality improvements, noise pollution reduction, and the ability of the streetcar to minimize distances (and hence save land value costs) to and from pedestrian areas and businesses, should also factor into cost analysis. Moreover, Milwaukee has an already-constructed streetcar Operations and Maintenance Facility, a completed Main Line, and five American-made Liberty Modern Streetcars. See also: Bell (2017) and Litman ("Evaluating public transit benefits and costs," 2020).

32. Award-winning, modern American-made streetcars and award-winning engineering: The Brookville Liberty Modern Streetcars are designed and built in Brookville, Pennsylvania, USA (Brookville, 2021). The rails used are American-made steel. In 2015, the Liberty Modern Streetcar won the Technical Innovation of the Year award for its onboard energy storage system (OESS) at the ninth annual Global Light Rail Awards in London. At the 12th annual Global Light Rail Awards in London in 2018, Brookville was awarded Manufacturer of the Year. The Hop and its engineers at HNTB Corp won the Engineering News-Record's Best Airport/Transit project in the nation in 2020. People who mistake the streetcar as something from the "1800s" don't understand that these are 21st-century vehicles with modern features, infrastructure, and operating techniques.

33. Proven ability to meet transit needs for people all over the world, including places like Milwaukee: There are hundreds of operating streetcar systems throughout the world that meet people's needs for transportation every day. Some systems have been operating for more than a century. A good comparison to help people understand why streetcars work in Milwaukee is Helsinki, Finland which has been running electric streetcars (called "trams") continuously since 1900. The climate of Helsinki is a bit colder and snowier than Milwaukee, and Helsinki's population is just under Milwaukee's population. Helsinki's modern tram network operates quite well today, and is set for "massive expansion over the next decade" (TheMayor.EU, 2021).

34. Benefits as public transit--economic, social, and environmental: The Hop streetcar is, of course, public transit and carries with it the general benefits that public transit brings to a community. Public transit benefits include energy and environmental benefits, economy and employment benefits, and health benefits (American Public Transportation Association). Rail benefits include "less traffic congestion, lower traffic death rates, lower consumer expenditures on transportation, and higher transit service cost recovery than otherwise comparable cities with less or no rail transit service. This indicates that rail transit systems provide economic, social, and environmental benefits, and these benefits tend to increase as a system expands and matures" (Litman, "Rail Transit In America: A Comprehensive Evaluation of Benefits," 2020).

35. Access to practical, day-to-day needs like grocery stores, a pharmacy, medical care, and community sites: The Hop streetcar brings people to grocery stores and a pharmacy along its current Main Line now. People from food deserts or who live far from these services can gain access. I can attest that it is much easier to bring bags of groceries onto the streetcar because of its level-loading, wide doors, and layout than onto a bus. There are several health clinics, exercise clubs, churches, and parks along The Hop's Main Line. (December, "MKE Streetcar 'The Hop' Destination Guide," 2021).

36. Equity opportunities: Rail-based public transit offers a way to rebalance the inequities that have been happening for nearly a century in the US and throughout the world: public expenditures for automobile-centric travel and development have dominated, oftentimes leading to the destruction or "cutting in two" of communities and social inequities. The high-quality transit experience streetcars offer reknits the urban landscape around people and transit and can start to rectify this imbalance. In the great tradition of cities throughout human history, streetcars can build the shared infrastructure upon which commerce, culture, enterprise, and civic life can flourish.

The Hop streetcar specifically is scaled at the neighborhood level, in terms of its connected walksheds, and thus bridges the walking and transit fabrics as described by Newman and Kenworthy (1999). Streetcars are the original generators of much of the transit fabric of the Milwaukee area (Canfield, 1972). A streetcar can operate in mixed traffic as well as dedicated right-of-ways. A streetcar in the corridor could fit in scale and purpose into larger-scale rail services such as connections to light rail stations or streetcar-train support (Naegeli et al., 2012). A streetcar exhibits the advantages of rail (Litman, "Rail Transit In America: A Comprehensive Evaluation of Benefits," 2020) at a people-oriented and neighborhood-level scale. A streetcar reknits the transportation fabric that was weakened when historic streetcars were removed. Many cities now are seeking ways to reknit these walking and transit fabrics.

A high-quality rail line could provide high capacity service, draw favorable attention from people, and provide a superior ride experience which draws ridership (Tennyson, 1989; Tawfeek and Gouda, 2015). Further, an emphasis on higher-density development along the corridor with an improved pedestrian experience can bring 27th Street up to its potential as a major development corridor for Wisconsin's largest metropolitan area and offer distinct opportunities unavailable anywhere else for business and living. The Hop streetcar has proven the capabilities of streetcars for emissions-free, high-quality transit that has operated in all weather--from the polar vortex to snowstorms--with safety and reliable service on Milwaukee streets. Moreover, The Hop streetcar has demonstrated how an emissions-free vehicle, on a fixed track allowing for predictable path travel, can more closely and safely meet pedestrian features and travel near pedestrians, such as the wide sidewalk area on the south side of The Milwaukee Public Market. The streetcar, unlike a bus, offers advantages for building pedestrian-oriented spaces and streetscapes along the corridor that closely interact with people because of the zero-emissions, low noise, and fixed track assuring the route of the vehicle. Further, the fixed track nature conveys permanence to riders and can support developers on the corridor who would wish to make long-term investments and business orientation at the transit stops.

In considering streetcar, Bus Rapid Transit (BRT), and Light Rail Transit (LRT) modes, research and experience have shown that all are successful public transit modes (McCunney, 2014; Brown, Nixon, and Ramos-Santiago, 2015; Tawfeek and Gouda, 2015). What is in question is the design purpose of improving the 27th Street corridor and, in particular, the land-use decisions (Schlickmann et al., 2017). The BRT versus rail question should be decided by the overall purpose of the transportation and the overall vision for how the corridor could transform equity and land-use outcomes. Currently, the automobile-orientation of 27th Street is clear. A re-orientation around pedestrians and walkable urbanism, served by streetcar with its proven ability to support the dense placement of people and features, opens the door for more development and more housing, affordable housing, car-free housing, transit-oriented development, and modern parking reform (Shoup, 2018). The outcome is not unknown: examples throughout the world show how greater community equity and prosperity can come about with superior transit, as transit itself is a shaper of cities (Newman and Kenworthy, 1999; Marshall, 2000; Reader, 2004).

Streetcar transit conveys to riders as well as developers that a permanent commitment is made to transportation, and this could be transformative. The durability of rail is like the durability of the street itself: a permanent commitment. By placing a bus service that has poorer rider acceptance, a poorer quality ride, and impermanence there, you are sending a different message: the status quo is perfectly fine and can reassert itself after a short makeover. I urge that our planning can seize this moment to create a unique streetscape, in the heart of the county, to set a bolder future vision that builds back better than what we have had before. For transportation, "cities can continue to lead the charge in helping the nation overcome massive transportation infrastructure maintenance, climate, and equity challenges" (Gore, 2021).

The 27th Street corridor offers a setting where the streetcar may offer faster service for more people than its current Main Line. The 27th Street corridor is a long, straight route that could allow service at the higher speeds possible for the Liberty Modern streetcar, up to 48 mph (77 km/h) (Brookville, 2021). The Kansas City streetcar is currently undergoing extension along a generally straight route "3.6 [5.8 km] miles south on Main Street, adding 16 stops and connecting the Downtown starter line to Midtown, Westport, the Art Museum District, the Plaza, and UMKC [University of Missouri--Kansas City]" (Kansas City Streetcar Authority, 2021). Spieler praises the Kansas City streetcar because it "stands out from its peers with a simple route that connects multiple activity centers" (Spieler, 2018). The engineering complexity and costs may be alleviated by a long, straight path along the 27th Street corridor. Advances in battery technology and the streetcar's hybrid power design already reduce overhead wire construction requirements (Booth, 2019). A dedicated right-of-way in certain areas may also address automobile speed concerns by supporting a road diet approach (Project for Public Spaces, "Technical Guidance on Road Diets").

The need to provide equity and access through high-quality transit in this corridor can be met by a streetcar. In particular, my observations of the streetcar as connecting walksheds places it at a neighborhood-serving level versus light rail which has larger distances between stations. As a resident of Milwaukee County, I ask that our planning process step up to the challenge and remake transit along the 27th Street corridor with a serious consideration of a streetcar along the full length of 27th Street or in phases from a starting point along the corridor that serves underserved communities and expands over the years further to the north and south. Such a design should also leave open the possibility of streetcar connections to light rail stations.

I make this comment based on my use of the streetcar and bus transit for years as well as examining transit research. A streetcar offers user-accommodating, emissions-free, and permanent infrastructure. The streetcar serves as a catalyst and support for development. The streetcar fits a niche between a regular bus and light rail, and its life-cycle cost comparison could be favorable. A streetcar route connecting the existing streetcar operations and maintenance facility at the Hop's facility near the Milwaukee Intermodal Station area would bring more neighborhoods into the reach of downtown destinations on the Hop's Main Line. In this way, the streetcar can continue to build the health, equity, livability, and prosperity of our community.

Respectfully,

John December

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