Read LRTDR’s full response to the Met Council’s SWLRT FEIS here.
Excerpts from LRTDR FEIS Response
220.127.116.11 Greenhouse Gas
The FEIS states: The Project operation will increase the GHG emission in the Twin Cities area by approximately 2,000 metric tons per year in 2040, compared to No Build alternative (FEIS, p 3-204).
LRTDR Response: In terms of GHG, it will be a net benefit to the State of Minnesota not to build SWLRT (FEIS Table 3.11-3). That is, per the FEIS, Southwest LRT adds to the annual total of GHG.
Put another way, even with the projected, very minimal 6500 cars off the road noted in the FEIS, in 2040, there would be a net GREATER increase of GHG annually with SWLRT than if the 6500 cars stayed on the road.
2.FEIS Executive Summary Purpose and Need
FEIS Executive Summary “Since the late 1980s, the Council has identified that the Southwest Corridor warrants a high level of transit investment to respond to increasing travel demand in this highly congested area of the region.”
LRTDR Response: Purpose of Proposed Project: An Investment in Suburbanization
In line with the national post – war pattern of suburban growth, per Minnesota Compass, the core cities of Minneapolis and St. Paul experienced a 38% drop in population while the suburbs grew 380% from 1950 to 1980. From 1980 until very recently, the core cities’ population remained unchanged, while the exurban and suburban population rings rose by over 50 %.  Eden Prairie, the SWLRT southwest terminus city located at a 12 mile distance from Minneapolis, provides an example of this suburban growth with its population rising 300% from 16,000 to 50,000 from 1980 to 2000 (SWLRT DEIS, 2012) and another 12,000 by 2013.
The Civil Rights Project at the Harvard Center for Community & Change described post-war suburbanization in Moving to Equity and linked income inequality and racial segregation to growth and development of suburbs located increasingly farther away from central cities.  It was in this context of ongoing suburbanization in the late 1980’s that the Met Council chose the Southwest Corridor as warranting a “high level of transit investment.”
At the time that planning for SWLRT began in earnest in the mid-2000’s, the Brookings Institution Metropolitan Policy Program issued Mind the Gap: Reducing Disparities to Improve Regional Competitiveness in the Twin Cities. The report found that while the Twin Cities has many assets that make it strong and competitive, “Underneath these broad regional successes are some disturbing social and economic disparities, demonstrating that progress is not widely shared.“  The report identified and called for the reduction of three sets of “gaps” or areas of disparity — among racial and ethnic groups, among different income groups, and between the central cities and the suburbs. The three gaps showed that the region’s prosperity does not benefit all residents or communities. 
These areas of disparity are interrelated and intersect in the gap between central cities and suburbs:
Place disparities, or differences between cities and suburbs (and among suburbs), result from uneven development that has led to concentrations of poverty in the regional core and concentrations of relative wealth in the outer suburbs. 
The two central cities have markedly different demographic patterns than the rest of the metropolitan area. While some older, inner ring suburbs are beginning to resemble the central cities in some respects, the region still displays a fairly traditional pattern of poorer, more diverse central cities surrounded by wealthier, whiter suburbs.
As SWLRT planning unfolded in 2005, the Mind the Gap study found:
Concentrated poverty—neighborhoods where the poverty rates are 40 percent or higher—is solely found in Minneapolis and St. Paul. In other words, there are no extremely poor suburban neighborhoods, only extremely poor central city neighborhoods. According to a study done by the DC Fiscal Policy Institute, the Twin Cities has the second starkest differential between city poverty rates and suburban poverty rates in the country. The central cities’ poverty rate is 4.5 times higher than the suburban poverty rate, which is a higher ratio than the Baltimore, Detroit, Cleveland, and Philadelphia metro areas (emphasis added). 
SWLRT as an answer to “increasing travel demand in this highly congested area of the region” was conceived and planned in this stark context of Twin Cities’ metro suburban and urban disparity.
- LRTDR rejects the following FEIS justification of SWLRT: This area of the Twin Cities experiences daily congestion on the roadway network. Provide a travel option to attract choice riders to the transit system, in an area of the region experiencing congested roadway connections between corridor cities and downtown Minneapolis (FEIS Executive Summary, p.2).
- LRTDR Response: The SWLRT project enacts the stark metro place disparity by prioritizing the most costly public works project in state history for the purpose of providing “a travel option to attract choice riders” who have caused the congestion produced by southwestern suburbanization.
Furthermore, the move to affluent and distant suburbs has been accompanied by an unacceptable and extraordinarily low carpool rate during commute hours between the Southwest suburbs and Minneapolis. An efficient use of the existing transit and transportation resources must be required of “this area of the Twin Cities.”
The FEIS ridership table 4.1-2 on p. 4-18 shows that SWLRT is expected to take only 6500 vehicles off the road by 2040. Attaining a 9% carpool rate among southwest metro drivers over the time period of the SWLRT planners’ time horizon of 25 years – only 520 new carpoolers per year – would achieve the same congestion relief at very little, if any, cost. A 9 – 10% carpool rate is typical for other metropolitan areas. This area of the Twin Cities and the entire metro should be expected to match what is achieved in other metropolitan areas before receiving an extraordinarily high and disproportionate level of transit investment.
SWLRT planning history can be seen as a repeated performance of the stark differential between city and suburb documented in Mind the Gap. A representative enactment is the “diagonal route,” described in the FEIS as a positive characteristic of SWLRT. Yet the diagonal route is not equally shared by city and suburb. On the one hand, the diagonal route was insisted on for Minneapolis by SWLRT planners as the fastest way into downtown jobs for suburban commuters, though key characteristics of that route were that it missed urban density, insulated suburban riders from major Minneapolis commercial areas and neighborhoods, and limited the opportunity for urban development. On the other hand, the diagonal route was abandoned and substantively changed at the southwest suburban end to serve business needs there:
“Early Southwest LRT plans [for Eden Prairie and Minnetonka] had the train remaining to the north on the existing railroad right-of-way it will use for most of its route from Minneapolis. “We pushed hard to get it down into our core jobs and commercial districts,” says Mayor Tyra-Lukens. 
In 2007, Minnetonka and Eden Prairie made it clear that routing SWLRT through the Hennepin County-owned recreational trails in their communities, comparable to the Kenilworth Trail in Minneapolis, would limit development and economic opportunities and be detrimental to their cities’ quality of life. Eden Prairie and Minnetonka were not allocated mitigation of a poor route. They “pushed hard” and got a better, more valuable alignment for their suburban cities.
Eden Prairie Mayor Nancy Tyra-Lukens described the purpose and need for the SWLRT and its alignment in Eden Prairie as follows:
“One of the largest software companies in the Twin Cities, HelpSystems, just told me it can’t fill jobs out here. We don’t want these businesses moving. It’s a competitiveness issue for us.” 
According to Mayor Tyra-Lukens, the SWLRT reroute out of the HCRRA trail was needed to keep businesses in Eden Prairie. This suburban economic strategy is directly contrary to the FEIS statement of Purpose and Need to “improve access and mobility to … the expanding southwest suburban employment centers.”
SWLRT as a strategy to keep or attract businesses to the southwest suburbs, rather than to provide needed transit to “expanding southwest suburban employment centers,” is reported in a recent Mpls/St.Paul Business Journal article (3/18/16), The Great Minneapolis Migration: As employers head downtown, suburbs play catch-up to add amenities to hold onto tenants. The article reported that over the past two years, more than 15 companies have announced relocations to downtown Minneapolis. A consequence of the shift by businesses from suburban to downtown office locations is a drop in demand for suburban office space. An office broker specializing in the southwest suburbs at Cushman & Wakefield/NorthMarq predicts the drop in demand for southwest suburban office space will improve with the proposed SWLRT line. He is cited as expecting “a bump in suburban office demand as light rail transit along the southwest corridor gets closer to opening in 2020,” echoing Eden Prairie Mayor Tyra-Lukens’ description of the need for SWLRT as “a competitiveness issue for us.“
- LRTDR rejects the FEIS depiction of SWLRT Purpose and Need: “to improve access and mobility to … expanding southwest suburban employment centers (FEIS Executive Summary p.2).”
- SWLRT as routed is a public investment in an amenity for the competitive position of private southwest suburban business. It is desired by Southwest suburbs and implemented as a strategy to retain their employment centers, not a public transit need to access expanding southwest suburban employment centers.
Thus, the proposed SWLRT route hooks at its southwest suburban end rather than continuing the diagonal route along the HCRRA-owned right-of-way. Prior to the route change in Eden Prairie, there was a citizens’ activist group there, Trails not Rails.  Citizen activism occurred early in SWLRT planning to preserve areas near the HCRRA Trail in Eden Prairie.  The Trail is now a valuable recreational greenspace surrounded by a golf course.
Therefore, in addition to the reroute “pushed for” and achieved as a strategy to enhance its business competitiveness, Eden Prairie has obtained an increase in its recreational green space with the HCRAA – purchased rail corridor. Eden Prairie and Minnetonka have roughly 2 to 3 times more open space acreage per person than Minneapolis. Hence, southwest suburban SWLRT routing enacts and worsens another element of urban and suburban disparity, which would be repeated by the adverse and degrading impact of SWLRT on the Minneapolis Chain of Lakes. Eden Prairie was publicized in Money Magazine’s “Best Places to Live” in September 2012. The magazine promoted the high quality of life in the suburb, listing $116,000 as the median household income and a coming “commuter rail project” as a reason to live there.
The Mind the Gap study strongly argued for reducing the “stark differential” of place and poverty between metro suburbs and the core cities on the bases of social equity and regional economic growth. Nonetheless, due to planners’ priority to improve the alignment in Eden Prairie and Minnetonka, $300 million in project costs were added early in the planning process, thereby increasing the overall SWLRT project budget from about $900 million to about $1.2 billion. As described in an article from 2009:
“Effectively, this is where Minneapolis finds itself, and the region is coming dangerously close to eliminating its best route option because of cost-effectiveness concerns. Of the three routes being considered for the Southwest Transitway’s alignment, one (#1A) has been dismissed by suburban officials because it won’t serve the city of Eden Prairie as effectively as the others, even though it would be cheaper to build (emphasis added).” 
The 30% suburban budget increase occurred at the beginning of planning and caused enormous and unrelenting pressure thereafter to keep costs down for the Minneapolis portion of the SWLRT alignment. The improvement in the southwest suburban alignment thus may be said to have played a causal role in determining a poor route in the city and therefore the metro as a whole.
The new suburban alignment out of the HCRRA Trail in Eden Prairie and Minnetonka also meant SWLRT must be built through wetlands there. The additional financial (as distinguished from environmental) cost of doing so was not made public until the spring of 2015 and then portrayed as part of $300 million of engineering “surprises” to SWLRT planners.  Significantly, the Met Council will not break down the most recent additional $300 million project costs by municipality. Therefore, information is not available regarding the total public transit dollar investment for Eden Prairie’s and Minnetonka’s SWLRT strategy as “a competitiveness issue for us. “ However, we do know that the environmental cost to wetlands is steep, and in fact, cannot be mitigated. As stated in the FEIS, the Met Council must purchase wetland mitigation bank credits to offset the damage caused by the route.