Archive for MTA Economics

With an improving economy, record high ridership and internal cost-cutting buoying the MTA’s bottom line, the transit agency announced that planned fare hikes for 2015 and 2017 would be less than expected. In budget documents presented to the Board today, the MTA noted that the biennial fare and toll increases will be reduced to produce an increase in revenue of around four percent, down from initial estimates of a 7.5 percent jump. Still, the budget rests on shaky assumptions, and as other interested parties make a move to claim some of the pie, these numbers could still shift before the hikes are implemented.

According to agency documents, an aggressive effort to limit the growth of expenses to keep pace with inflation allows the MTA to realize savings that can be reinvested in the system. The MTA has already announced service increases on eight lines set for June, and even though constant price increases are tough to swallow, the fare hike reduction is good news for the straphanging public.

“We try to keep costs down in order to minimize the financial burden on our customers, and as this financial plan shows, we are succeeding in that effort,” MTA Chairman and CEO Thomas F. Prendergast said. “Our customers want value, which is quality and quantity of service, and that service has to be reliable and safe. Through this financial plan, that’s what we work to provide.”

In addition to these giveaways, the MTA has other plans for its financial flexibility. The MTA plans to invest approximately $80 million in the unfunded pension liabilities for the LIRR and make addition investments in other unfunded post-employment benefit obligations, thus realizing savings in the long-term as well.

Still, risks remain as the budget is tenuously balanced on the back of an assumption of net-zero wage increases, a point hotly contested by the TWU. The MTA will look to achieve this net-zero goal through a combination of a wage freeze, staff reductions, workrule efficiency gains and benefit reductions, but union officials have already tried to lay claim to some of these dollars. “They’re tossing a few crumbs at the public and expect to be patted on the back. It’s pretty outrageous,” TWU Local 100 President John said to The Post. “Both the workers and the riders deserve better.”

Samuelsen claimed the MTA should use all of the financial flexibility to give workers a raise and avert the fare hikes. His statements essentially ignore the fact that doing either of those — let alone both at once — would effectively deplete whatever cash surplus and financial wiggle room the MTA has. For now, though, the news is good, but as with all things MTA, the economics could change in a flash.

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Vanderbilt Hall may soon host a restaurant. (Photo via flickr user Bitch Cakes)

As the 100th anniversary of Grand Central continues, the historical rail terminal is still set to see some new restaurants in some of its unique spaces. Nearly 18 months after we first learned that the MTA was looking to lease out additional spaces, Crain’s New York once again reports that the restaurant planned for part of Vanderbilt Hall will soon become a reality. The MTA will not reveal any details about interested parties, but sources told Crain’s that a deal is in progress.

As reports last year noted, the Vanderbilt Hall area contains approximately 12,000 square feet of space and is currently used for everything from squash games to ice rinks to holiday markets. The restaurant lease will likely take over one half of that space, and the other half will serve as a rotating event area. The annual holiday market, for instance, will continue but may be only half the size. Per reports last year, the restaurant will be open seven days a weekand will not be a chain. We’ll know more soon.

Categories : MTA Economics
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The New York State Court of Appeals has upheld yet another appeal of the MTA Payroll Mobility Tax, delivering another blow to Nassau County Executive Ed Mangano’s never-ending attempts to starve transit. Despite Mangano’s second such loss and a dismissal by the court that effectively means no constitutional question was directly implicated by the case, the Tea Party-backed Nassau County official, will continue to spend taxpayer dollars on another avenue of appeal.

Yancey Roy of Newsday broke the news:

New York’s top court threw out a lawsuit Thursday seeking to overturn the controversial MTA payroll tax on constitutional grounds. But Nassau County Executive Edward Mangano, who filed the suit, still has 30 days to appeal on other grounds.

The state Court of Appeals dismissed Mangano’s lawsuit without comment, upholding a mid-level court ruling that the tax, paid by employers in the 12-country region served by the Metropolitan Transportation Authority, is constitutional…

Court spokesman Gary Spencer said Mangano has 30 days to file a motion asking the court’s permission to argue the case. Nassau County attorney John Ciampoli said Mangano definitely will appeal. Ciampoli said the payroll tax was “fundamentally defective in how it was adopted” by the state Legislature.

At this point, Mangano is barking up the wrong tree. He’s not going to get the tax overturned, and his efforts to continue this lawsuit are bordering on laughable. If he loses his reelection bid this November, I’d expect Tom Suozzi would drop the appeal. Polling, however, is very close for this race.

More telling, though, is this comment on the Newsday article. “This tax is a hideous intrusion on the rights of Long Islanders who do not use the MTA,” one commenter said. If that’s not a telling glimpse into the provincial and siloed viewpoints of Nassau County residents who look down upon transit without realizing its true impact, I don’t know what is.

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When the MTA announced its move to purchase catastrophe bonds as a hedge against future storm surges, it raised a few eyebrows among both the reinsurance world and transit advocates. The catastrophe bond market is a highly specialized one, and the MTA had become the first major public entity to wade into it. Now, as details emerge the bond issuance appears to offer investments a big payoff and provides the MTA protection against unlikely events. It is, essentially, a private insurance.

In the first in-depth piece to examine the catastrophe bond sale, Tessa Stuart of The Village Voice looks at the big bet and the big payoff. As she frames it, after Sandy when the MTA had to turn to insurance to cover billions of dollars of damage, it was clear that the agency’s premiums would be unaffordable moving forward. And so to test the market, the MTA turned to catastrophe bonds. She writes:

That’s how the fate of the subway system ended up in the hands of just 20 investors. If a hurricane were to descend on New York tomorrow, repairs to the subway system would be paid for with money put up by those investors, who bought shares of a so-called catastrophe bond the MTA sold this past summer. It’s not philanthropy; it’s an investment. The same 20 bankrollers stand to make millions, provided another Sandy doesn’t hit tomorrow or anytime in the next three years.

Before Sandy, the MTA owned an insurance policy worth $1 billion. After the storm, says the agency’s director of risk and insurance management, Laureen Coyne, “It was impossible to get that kind of coverage.” Even half a billion dollars’ worth would have cost twice as much. The MTA was particularly concerned about its protection in the event of another flood…

Without a lot of options, the MTA dove headfirst into the small, strange catastrophe bond market, where an estimated 100 investors worldwide do $16 billion worth of deals…In order to sell the bond, the MTA’s in-house insurer, First Mutual Transportation, enlisted a law firm to create an offshore entity dubbed MetroCat Re, located—for “various legal and tax reasons,” Coyne says—in Bermuda. All the money involved in the bond arrangement goes through MetroCat Re.

Essentially, the bond is a simple high-stakes bet: If a catastrophic hurricane causes a Sandy-magnitude storm surge on or before August 5, 2016, investors lose every cent they ponied up. No hurricane, and they get all of their money back, plus a return that will top 13.5 percent.

The MTA put the bond up for sale in July, expecting to sell $125 million in shares, but the interest was overwhelming. The agency ultimately sold more than $200 million to just 20 investors. (Ostrovskaya describes the buyers not as individuals, but “pretty much specific catastrophe bond funds that specialize in this type of investment.”)

The surge protection supplements the $500 million in insurance the MTA has purchased to cover perils such as wind and fire. That policy costs the MTA $46 million a year.

It’s easy to see why the catastrophe bond was popular—it’s an incredibly lucrative proposition. A $10 million share could pay off more than $1.35 million in just three years. The money comes straight from the MTA, which makes quarterly payments into a trust, in much the same way that it would pay an insurance premium. At the end of three years, if disaster hasn’t struck, the investors cash out.

Stuart’s piece goes on to explain how a storm surge high enough to trigger the bond conditions is rather unlikely, but I think that’s besides the point. The only way the MTA could insure against future losses was through these bonds. All told, the various investors could make a combined $27 million — a total similar to what the MTA is paying for insurance — and the agency gets more coverage than it can from insurance companies right now. It’s an intriguing situation, and it’s the one time we’re hoping the MTA has to shell out the money in the end rather than suffer through another catastrophic storm.

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The MTA's debt problem, in handy chart form.

The MTA’s debt problem, in handy chart form.

The MTA is sitting on top of a substantial debt bomb. By 2017, the amounts owed by the agency to its creditors will reach $39 billion, and while much of this debt comes from capital expenditures, debt service payments — which are expected to reach $3 billion annually by 2018 — burden the operating budget instead. These figures do not account for the MTA’s next capital plan of around $28 billion, a significant portion of which will be funded through the issuance of more debt.

Agency officials are well aware of the debt problem. They know that the MTA’s lending capabilities may soon be maxed out, but a perfect storm of conditions have left the agency with few other choices. With drastically reduced direct contributions from the city and state, the MTA has to bond out maintenance projects that keep the system running or else risk a slide back into the conditions of the malign neglect of the 1970s. These problems aren’t new or a secret.

Debt, though, is boring. It’s complicated and abstract, and few people from riders to consumers of the news truly care about the abstract debt on the books of a state bureaucracy. What they care about instead are the fares and the service. In a utopian world, customers pay less for more service; in the real world, customers are paying more for incremental service upgrades. Sometimes, they pay more just to maintain the current service levels. Fare hikes rile up the angry masses and provoke outrage, some warranted and some not, from politicians. Fare hikes, of course, are tied to debt, but that’s a level of complexity that most people don’t need or want to care about.

Still, certain government bodies should rise above the populist calls against fare hikes. Whenever the MTA’s budgetary conditions improve, as they recently have, anyone with a megaphone yells for fare hike reductions. It may make for happier customers and, perhaps, more riders, but it does not make for sound fiscal policy. Today, from New York State Comptroller Thomas DiNapoli, we have one of those calls.

In a generally positive report issued today [pdf], DiNapoli found that, after years of troubles, the MTA budget looks pretty good. A combination of unexpected financial contributions and aggressive belt-tightening has led the MTA to realize nearly $2 billion in resources. Over the past seven months, the MTA has reduced out-year gaps to a total of $240 million (down from $638 million) and did so through higher tax revenues, lower pension contributions, lower energy costs, lower debt service and lower health insurance costs. Internal restructuring and cuts as well as an attempt to lower paratransit expenditures has contributed as well.

Yet, even while acknowledging the MTA’s debt problems, DiNapoli chose to focus on how fare increases have outpaced inflation over the past decade and how avoiding planned fare hikes in 2015 and 2017 should be a priority. It is a truly populist stance from someone who is supposed to be responsible for maintaining the fiscal integrity of state agencies. “The MTA’s financial outlook is much improved,” DiNapoli said in a statement. “While funding the next capital program and improving services are critically important, reducing the size of planned fare and toll hikes must also be considered. There is plenty of time before the next scheduled fare increase for the MTA to refocus its efforts on reducing waste, which could go a long way toward easing the financial burden on commuters.”

The MTA’s problems stem from a history DiNapoli is in danger of repeating. For decades, politicians kept the subway fares artificially low at five and later ten cents. Only through recent aggressive fare hikes have the historical inflation trends matched the five-cent fare in 1904 to the current fare in 2013. Fares over the last seven years have risen 47 percent with no corresponding inflationary jump.

But the agency finds itself between that proverbial rock and a hard place. The best and most reliable way for the MTA to generate more revenue is through fare increases, and without a more stable funding stream, fare increases will continue. It’s also disingenuous for the state comptroller to complain on one page about skyrocketing debt and on the other call for a moratorium on fare increases.

So straphangers and the MTA are stuck. We’re stuck with fare hikes that won’t step and debt obligations that won’t simply disappear. It would be nice to keep fares at current levels for longer than 24 months, but it wouldn’t be a prudent fiscal decision on behalf of the agency tasked with overseeing our transit system to do so.

Categories : MTA Economics
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The MTA missed its overtime spending projects during the first half of 2013 by nearly $70 million, according to agency budget documents released yesterday. Thanks to a combination of employee vacancies, maintenance and weather emergencies largely driven by Transit’s response to the damage inflicted by Sandy, overtime spending hit $368.5 million from January-June, a variance of $68.9 million over what the MTA had originally budgeted for this year. It is unclear how this unanticipated expense will impact the year-end budget.

According to the special report released yesterday [PDF], weather was a driving factor in this jump. Of the $68.9 million, $29 million stemmed from responses to weather issues, and $20 million of that is directly attributable to Sandy. “Work included, but was not limited to, supplemental bus and shuttle service for subway and train lines that were damaged, repair of signals in flooded areas that were immersed in salt water, station repairs, and extensive damaged track work.” Vacancies and employee availability contributed $10 million to the overtime expenditures as well, but these costs were partially offset by payroll savings.

The report did not contain any clear cut steps to reduce these overtime expenses and urged agency leaders to reassess future budget projects. The report called for an aggressive attempt at filling vacancies and expanding the “pool of employees-in-training for critical operating positions,” but overall and despite a dip in 2010, overtime expenses, mired in the upper $500 million level annually, remain a big concern.

Categories : Asides, MTA Economics
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It was back in the waning days of June when the State Senate and Assembly both passed a lockbox bill with strong protections for transit funding. This was the second time that the bill had passed the legislature, and while Gov. Cuomo had gutted the protections that prevented a raid on transit financing last time around, advocates were optimistic that the bill would gain Cuomo’s signature. Since then, though, we’ve waited. And waited. And waited.

Lately, though, there is a reason for some optimism as upstate newspapers, not usually in favor of anything that bolsters the MTA — they amazingly view it as a drain on the rest of New York State — have lined up behind the lockbox. Since the bill protects all transit money and not just that earmarked for the MTA, upstaters have reason to argue for a signature. The Buffalo News voiced its support this week, and The Press-Republican from Plattsburgh sounded off last week.

Over at Capital New York, Dana Rubinstein sees this groundswell of support as an indicator that Cuomo will soon have to sign the bill. If everyone in New York state wants these modest protections in place, the governor will have to step in and govern soon enough.

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The MTA budget documents released yesterday show how aggressive cost cutting and fare hikes could eliminate nearly all potential deficits through 2017. [pdf]

The MTA budget documents released yesterday show how aggressive cost cutting and fare hikes could eliminate nearly all potential deficits through 2017. [pdf]

The MTA unveiled a revised draf of its four-year financial plan on Wednesday, and while budgets are not particularly sexy, fare hikes are. This plan is chock full of fare hikes as the MTA’s fragile financial outlook relies on fare hikes every two years for the duration of the plan. Just how long, I have to wonder, will New York’s transit riders begrudgingly accept these fare hikes before it becomes a major political issue?

In plans released yesterday, the MTA still projects some deficits through 2017, but as February’s numbers showed alarming negative balance sheets, the July numbers are significant better. By 2017, the MTA expects to face a deficit of just $100 million — down from over $300 million — but these projections are based on a series of assumptions that may not come true. Riders are going to shoulder a significant amount of costs as fares continue to increase, and anything that rocks the MTA’s financial boat could be disastrous for the agency.

For the public, the fare hikes are the bad news, and they rightly dominate the media coverage. After fits and starts of raising the fares only when the budget looked dire, the MTA has instituted a policy of biennial fare hikes ideally tied to inflation. After a fare increase in 2011, the MTA jumped their prices by around 7.5 percent this year and plan to do the same in 2015 and 2017. Both hikes will be for around 7.5 percent as well, and without these fare increases, the MTA’s financial outlook is a negative one indeed.

If all goes according to plan, then, the MTA’s looming price increases will generate significant revenue for an agency looking at out-year projections that are very, very red. In 2015, the next fare bump will bring in over $400 million, and when the cost of a subway ride jumps up again in 2017, the total generated from the next two fare hikes will be a hair under $1 billion annually. Without the fare increases, the MTA’s deficit would be insurmountable. As such, the city’s riders — all 5.6 million of us daily — are the only thing keeping the subway system afloat.

Outside of these fare hikes, though, nearly all of the other assumptions are not sure things. The only sure thing is a concerted effort to cut internal costs. The MTA anticipates that, by 2017, it will have eliminated $1.3 billion in annual recurring costs, thus achieving internal cost-cutting projections first put forward in 2009. That’s a laudable goal for an agency that has long operated with much bloat, but more could be cut if operations were further streamlined.

Beyond these measures, though, the MTA is expecting a net-zero increase in labor costs over the next four years. While the MTA has realized such savings over the past few years, the TWU’s contract situation remains unresolved, and a net-zero reality saves just $300 million annually by 2017. Meanwhile, pension and healthcare costs are expected to jump by nearly 10 percent over the next four years and are among the biggest uncontrollable costs currently on the MTA’s books.

Beyond fares and labor savings, the MTA is relying on dollars largely outside of their control. Operating costs will increase as the 7 line extension and then Phase 1 of the Second Ave. Subway open, and the agency’s insurance rates took a huge hit after Sandy. Agency officials said yesterday that the MTA is getting half its previous coverage for twice the cost. Meanwhile, revenue from dedicated and federal contributions remain subject to the push and pull of the New York and U.S. economies.

Finally, the so-called “longer term vulnerabilities” come into play. The MTA will launch a new capital program in 2015, and it will likely be funded through bond issues and more debt. Pension, healthcare and paratransit costs are spiking upwards as New Yorkers live longer with less mobility, and weather mitigation and protection efforts will put a strain on the budget. It’s a never-ending scenario of investments.

So what does this all mean, you may ask. After all, budget forces and pure numbers are the ultimate in transit wonkery. The final picture, though, is a simple one: New York’s transit riders are going to be asked to shoulder an ever-increasing portion of the costs. Absent direct state investment, the best way for the MTA to raise money and increase its revenue is through fare hikes, and ridership, which recently reached an all-time high, has shown no signs of abating. People need the subways, and the MTA needs money. So we’ll get fare hikes in 2015 and 2017 and likely in 2019 and 2021 too. Until New Yorkers start agitating louder for an end to fare hikes, they are, for better or worse, the only route to budget stability.

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As part of the MTA’s plan to spend $40 million in unexpected state revenue on its customers, Transit will expand weekend service on the M to Manhattan and will increase G train service during the afternoon rush, as outlined in its line review. Gov. Andrew Cuomo announced these enhancements as well as some added bus service that will total $7.8 million, and the MTA plans to invest another $5.9 million in the customer experience and station environment as well.

“For the second year in a row, the state has invested in significant enhancements and expansions to our state’s transit system that will improve the experience of the eight million commuters who use the MTA,” Governor Cuomo, who continued his streak of taking credit for the MTA’s good news, said in a statement. “In the last two and a half years, our administration has made real improvements to the nation’s largest public transit system, implementing reforms that have improved services and made the MTA more efficient by reducing costs, cutting waste and putting the needs of straphangers and commuters first.”

According to the release, these service improvements will benefit nearly 90,000 passengers daily. G trains will operate every eight minutes from 3 p.m. to 9 p.m. on weekdays, cutting headways down from 10 minutes. On weekends, M trains will run from Middle Village, Queens to Essex/Delancey, providing riders with a direct connection to the F. Currently, M riders must make two transfers — from the M to the J and the J to the F — for service into midtown and points north. The M will not operate north of Essex/Delancey or along the Queens Boulevard line.

The other half of the investment picture involves nearly $6 million for other improvements. Transit will hire more cleaners for tracks and stations and will begin to adjust turnstile and Metrocard Vending Machine layouts as well. I hope to have more on these efforts later in the week.

Additionally, Transit will restore some bus routes lost to the 2010 cuts and beef up service on other lines. The newly restored routes include the B37 and B70 in Brooklyn, weekend M8 and Q31 service, Sunday Q77 buses, and additional hours of operation for the S93. The MTA also plans to add a yet-to-be-determined Select Bus Service route and will study bus service in Co-Op City to identify routing gaps and potential solutions. I question the wisdom of restoring service along bus routes that didn’t have the ridership to support it, but perhaps the attention devoted to these lines over the past two years will drive up ridership.

Outside of the city, the LIRR will invest $2.6 million in added service as well. Trains will run every 30 minutes on the weekends to and from Ronkonkoma and Port Washington. Weekend service to Greenport will be extended, and five peak-hour weekday trains will be added on crowded routes. Metro-North has a more modest ask as the railroad will get an additional $1.7 million to “add real-time customer information displays at all of its stations in New York State by 2020.”

For the MTA’s customers, this news is good. After years of service cuts, expanded service is welcome even if the subway enhancements are limited to two lines with relatively low ridership. The fundamental problems of comprehensive access and more frequent service on lines at or near capacity are side-stepped in this plan, but on the other hand, the MTA had only limited resources for expanded service. Officials acknowledged too that the long-term financial picture remains unsettled, at best.

“We have listened to our customers, and we are responding with more bus, subway and commuter rail service as well as enhancements to make that service more reliable and more enjoyable,” MTA Chairman and CEO Thomas F. Prendergast said in a statement. “We are committed to aggressively reducing our costs, and to strengthening service whenever we have sustainable resources to do so. But our Financial Plan remains fragile, and our financial challenges – both short and long term – are numerous. The revised Financial Plan puts our customer needs first while also allocating resources to longer-term challenges like reducing pension liabilities, lowering retiree health care costs and providing initial funding for our next Capital Program.”

Categories : MTA Economics
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Forest City Ratner pays $200,000 a year to append the Barclays Center name to the Atlantic Ave. subway stop. (Photo by Benjamin Kabak)

The MTA is set to unveil a series of budget documents this week that will set the stage for the next few years’ worth of conversations. They’re unveiling revised estimates for the current capital plan based on the need to spend money to repair the system and mitigate the impact of future storms and surges, and they’re keeping in an eye on the next twenty years of system growth as well. I’ll be taking a closer look at these documents this week, but one theme is a constant: Where will the MTA get the money to do whatever it is it wants to do?

One way the MTA won’t get money is through station naming rights deals. The agency needs billions of dollars, and even the most lucrative naming rights deal in the U.S. is worth only around $1 million annually. The MTA’s one current naming rights deal for a subway station is netting the agency a whopping $200,000 a year. But that’s not stopping the MTA from putting itself out there. This week, as part of the July board meetings, the MTA is formalizing its station naming strategy, and I think it gets everything right. Whether it can make money from the effort remains to be seen.

The new guidelines will be voted on this week, and they are available as a pdf on the MTA’s website. The MTA is consolidating the naming rights process and procedures so that Jeffrey Rosen, the head of the agency’s real estate department, and the new policy will not apply to directional signage, changes to the street grid or advertising campaigns that have no impact on a station name. It will apply to any other situation where an advertiser wants change “the official designation” of any MTA facility. This can include signage, maps and on-board announcements similar to the way Barclays Center has replaced Pacific St. at the Atlantic Ave. subway complex.

By putting forward this proposal, the MTA says it wants to receive “fair value” for the rights to name its stations. At the same time, the agency wants to “respect the historic nature” of its stations — which is less of a concern than the third factor: ensuring that customers can “safely and efficiently navigate the MTA system.” The third qualification I’ve stressed repeatedly, and it’s why SEPTA’s naming rights deal fails. AT&T Station — the replacement name for the Pattison station — tells a rider nothing about the station; it could be anywhere. But for its flaws, Atlantic Ave./Barclays Center carries a major destination in the sponsored station name.

With these policy goals in mind, the MTA set forth its standards. It will require “a compelling nexus between the Facility and the Sponsor” for any naming rights deals. “Requests for renaming,” the policy says, “will only be accepted from Sponsors with a unique or iconic geographic, historic or other connection to such [station] that would be readily apparent to typical MTA customers.” In other words, advertisings just looking to slap their names on a station won’t be able to do so. The Tropicana Station at Bryant Park won’t become a reality, but if Macy’s, for instance, wanted to buy out the Herald Square station, the MTA may listen. This limitation could eliminate many potential advertisers before the MTA even has the chance to discuss money.

If any naming rights venture gets this far then, the next issue concerns value. Considering how naming rights deals are tough to come by, it’s hard to say what “fair value” means in any context, but in addition to pure dollars, the MTA will also consider promised capital upgrades made by the sponsor or capita upgrades taken on by the sponsor in exchange for the naming rights. In essence, the MTA is creating something of an Adopt-a-Station program. How this works in practice rather than theory again remains to be seen.

Matt Flegenheimer of The Times reported on this plan over the weekend, and he had the chance to gain more insight into the process. MTA advisers recognize that transit agencies across the nation are hoping to draw money from naming rights, and one of MTA CEO and Chairman Tom Prendergast’s right-hand men claimed that “from time to time,” advertisers have expressed an interest in making a deal.

The policy, the MTA says, is to protect its customers too. “We don’t want to be confusing people,” Allen Cappelli, an MTA Board member, said. “There are neighborhoods where I would be very hesitant because of the geographic significance.” The MTA also won’t rename stations for people, living or dead. (Sorry, Ed Koch.)

This all sounds well and good. Yet, I can’t help but think it’s all for nothing. I’ve followed this issue for years, and nothing much has come of it. Madrid recently renamed an entire line for just €1 million a year while Boston has unsuccessfully put its station names up for sale. Austin, Toronto, New Jersey, D.C. and Chicago all want someone to pay for their stations, but very few people are biting. It’s too hard to overcome the stigma of being associated with something most people love to hate for these deals to be worthwhile. Maybe the MTA can realize some dollars, and they have a solid policy in place. But it’s a policy more like than not to go untested over the years.

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