Executive Summary
The Question of Independence in Infrastructure Research
The multi-billion-dollar Gateway Program for Penn Station—America’s busiest rail terminal—represents a generational infrastructure investment that demands rigorous, objective analysis. Yet a critical conflict undermines the evidence base: Amtrak, Gateway’s primary beneficiary, directly funds the Regional Plan Association’s advocacy and research promoting the project.
Key Findings:
- Public records document $850,000 in Amtrak funding to RPA over three years explicitly for the “Build Gateway Now” coalition.
- This coalition’s stated purpose includes producing “original research” and advocacy efforts to make it “CLEAR IN THE PUBLIC EYE THAT THE GATEWAY PROGRAM MUST BE BUILT.”1
- RPA’s resulting analyses consistently maximize Gateway’s benefits, including projections of $445 billion in economic benefits, while emphasizing catastrophic consequences of inaction.2
- These analyses often lack methodological transparency, preventing independent validation of their claims.
- Amtrak’s own data systems suffer from well-documented reliability issues, further compromising the foundation for these analyses.
- Alternative operational approaches like through-running—standard practice in global high-capacity rail networks—receive inadequate consideration despite their potential to deliver comparable benefits at lower cost.
Implications:
When project proponents fund research advocating their own initiatives, the distinction between independent analysis and promotional material blurs. This erodes public trust and hinders informed debate about the optimal allocation of scarce public resources.
Recommendations:
Decision-makers must demand analytical independence through full methodological transparency, truly independent third-party reviews, and heightened scrutiny of proponent-funded research. Funding entities should separate research from advocacy, while non-profits must strengthen conflict management protocols3 and diversify funding sources.
Infrastructure of this magnitude requires evidence beyond reproach. The integrity of the analytical process is not merely a formality—it is essential for responsible stewardship of public resources and maximizing the potential of our regional rail network.
Where Ambition Meets Obstruction
Penn Station stands as the indispensable nerve center of the Northeast Corridor, functioning as America’s busiest transportation hub and the most vital rail segment in the Western Hemisphere. Its operational capacity directly influences the economic vitality of the entire Eastern Seaboard, serving as the primary conduit for both daily commuter flows and intercity travel. With over 200,000 passengers navigating through its concourses on approximately 450 daily trains, Penn Station anchors the economic dynamism of a tri-state region whose contribution to national GDP is disproportionately significant.
Despite this critical importance, Penn Station exists as a monument to operational fragmentation. Three distinct railroad entities—Amtrak, NJ Transit, and Long Island Rail Road—operate within a shared physical infrastructure while maintaining separate operational protocols, equipment standards, and institutional priorities. This fragmentation manifests in a constant struggle for limited track and platform capacity, creating a system that functions despite its design rather than because of it.
The Gateway Vision and Its Proponents
The operational constraints and aging infrastructure have generated decades of calls for transformative change. The Gateway Program represents the most ambitious response to these challenges, encompassing new Hudson River tunnels, expanded track capacity, and comprehensive infrastructure upgrades. As the most significant rail infrastructure undertaking in generations, Gateway promises to fundamentally reconfigure trans-Hudson capacity, with implications reaching throughout the Northeast Corridor’s operational framework.
Within this high-stakes infrastructure conversation, the Regional Plan Association (RPA) has positioned itself as Gateway’s preeminent institutional champion. Through a systematic campaign of research publications, media engagement, and coalition-building, RPA has consistently advanced the narrative that Gateway represents the only viable path forward for regional rail mobility. Their latest economic analysis, released just this week, projects unprecedented economic benefits from the program’s implementation—figures that have rapidly become central to public discourse around the project.2
The Critical Question of Analytical Independence
Behind the technical debates about tunneling methods and track configurations lies a more fundamental question about the integrity of the planning process itself. Public records reveal a direct financial relationship between Amtrak—Gateway’s primary operator and institutional beneficiary—and RPA’s advocacy efforts. This relationship, formalized through substantial funding to RPA’s “Build Gateway Now” coalition, explicitly connects Amtrak’s financial support to both research production and advocacy campaigns.1
This intertwining of institutional interests raises profound questions about analytical independence in infrastructure planning. When the entity that stands to operationally benefit from a project directly funds the research advocating for that same project, the boundary between objective analysis and institutional promotion becomes dangerously blurred. What remains largely unexamined in public debates focused on construction timelines and engineering specifications is the integrity of the very information ecosystem shaping decision-making.
The future of Penn Station will be determined not merely by concrete and steel, but by the quality and independence of the analytical frameworks guiding investment decisions. As billions in public funds hang in the balance, the trustworthiness of the evidence base becomes as critical as the infrastructure itself. This is ultimately not just a question of transportation engineering, but of accountability, transparency, and the public interest at the highest levels of regional planning.

Funded Advocacy
The mechanism through which Amtrak’s financial support underpins RPA’s Gateway efforts is the “Build Gateway Now” coalition. Launched by RPA, this coalition unites a diverse array of over 40 civic, business, and labor entities, all aligned in their commitment to seeing the Gateway Program constructed. RPA functions as the strategic and operational engine for this group, directing its activities.
These activities, as candidly outlined in RPA’s Form 990 tax filings, leave little room for ambiguity regarding their purpose. Under the heading describing the coalition, the filings detail extensive efforts: “original research,” comprehensive “communication efforts (social media, op/eds, digital public engagement tools, regular contact with the media),” and direct “advocacy efforts (testifying at Gateway Development Commission Board meetings, lobbying in Washington DC, hosting press conferences and other rallies).”1 The unequivocal objective: to make it “CLEAR IN THE PUBLIC EYE THAT THE GATEWAY PROGRAM MUST BE BUILT.”1
The source of funding for this explicit campaign is equally clear: “OUR WORK IS SUPPORTED BY AMTRAK.”1 The financial commitment is documented in two grants: an initial $350,000 covering an 18-month period from January 2022, followed by a renewed and increased commitment of $500,000 for the 18 months commencing in January 2024. This aggregates to $850,000 over three years directed from Amtrak to RPA specifically for the Build Gateway Now coalition’s activities.
Table 1: Amtrak Funding to RPA for Build Gateway Now Coalition
Grant Period | Amount | Notes |
Jan 2022 – Jun 2023 | $350,000 | Initial 18-month grant (Form 990 2022) |
Jan 2024 – Jun 2025 | $500,000 | Renewal & increase (Form 990 2024) |
Total | $850,000 | Funding explicitly “supported by Amtrak” |
This structural arrangement presents an inherent and profound conflict of interest. Independent, objective analysis requires a distance from the entities that stand to benefit directly from the outcome of the analysis. When a funder—in this case, Amtrak, a primary operator and beneficiary of Gateway—provides funding explicitly for “research” and “advocacy” aimed at ensuring a specific project “MUST BE BUILT,”1 the integrity and impartiality of the resulting research are inevitably called into question. The purpose of the research risks shifting from informing policy to supporting a predetermined campaign objective. This situation squarely aligns with standard definitions of conflicts of interest, where external interests compromise professional judgment and objectivity.3
The Build Gateway Now coalition thus functions not merely as a forum for consensus-building, but as the operational vehicle for a well-funded campaign. Research outputs produced under its umbrella become, by definition, components of this advocacy effort. While such relationships exist across various sectors, the explicit nature of the funding’s purpose and the direct benefit to the funder in this instance demand a level of critical scrutiny that goes beyond standard disclosure.
Claims Under Scrutiny
Given the direct financial ties between Amtrak and RPA’s advocacy arm, a critical lens must be applied to the research outputs promoted to support the Gateway Program. The report “A Preventable Crisis: The Economic and Human Costs of a Hudson River Rail Tunnel Shutdown,” released in February 2019, stands as a prime example, having significantly influenced the public narrative and political debate.4
This report posited a dire scenario: a hypothetical, multi-year partial shutdown of the antiquated North River Tunnel, necessitated if new capacity wasn’t built first. Its central aim was to quantify the economic devastation of such an event. The resulting figures were stark and widely cited: at least $16 billion in lost national economic activity, $7 billion in lost tax revenue, and a breathtaking potential decline of $22 billion in regional homeowner property values, predominantly in New Jersey.4 These dramatic figures fueled a sense of urgency, framing Gateway as an economic imperative rather than merely a transportation project.
Yet, despite its significant impact on the public debate, the “A Preventable Crisis” report exhibits methodological characteristics that lean heavily towards advocacy rather than disinterested analysis. A crucial limitation is the absence of complete methodological transparency; the detailed calculations, specific data inputs, and the precise functioning of the models used to generate these multi-billion dollar figures are not publicly available for independent verification. While a companion document outlines assumptions, the opacity surrounding the core analytical process hinders a truly rigorous external assessment.5
The report’s reliance on a single, maximalist scenario—a four-year shutdown with a 75% reduction in peak capacity—further suggests a focus on maximizing perceived threat. Presenting such an extreme outcome as the primary consequence of inaction, without a broader range of scenarios, probability assessments, or robust sensitivity analyses on key assumptions, is characteristic of advocacy designed to compel immediate action. Several assumptions within the analysis appear calibrated to inflate projected costs, such as the heavy reliance on speculative home value losses extrapolated from previous RPA studies showing value increases due to transit improvements, a linkage that is highly speculative and overlooks myriad other factors influencing real estate markets.5
Alarmingly, the core operational assumption—the severity of the capacity reduction—was based on “public projections from Amtrak,”6 meaning the analysis relied on data provided by the very entity funding the advocacy effort. The report also omits potential mitigating actions by transit agencies, which, while incurring costs, would likely lessen the overall negative impact.
While the report acknowledges certain unquantified costs, its simultaneous heavy emphasis on these massive, speculative figures raises questions about selective analysis. The title, the focus on catastrophic outcomes, and its timing during critical funding debates strongly indicate the report’s primary function was to serve as a powerful advocacy tool, designed to generate political pressure by framing inaction as economically ruinous. This aligns perfectly with the “advocacy efforts” and the mandate to declare that Gateway “MUST BE BUILT” as described in the Amtrak-funded coalition’s stated purpose.1
This pattern persists in RPA’s latest economic analysis, projecting $445 billion in total economic benefits and 46,100 jobs sustained on average from 2023 to 2060. While employing a recognized tool, REMI TranSight, such astronomical figures—$445 billion equates to roughly 1.3% of the entire 2024 US GDP—demand intense scrutiny of the underlying assumptions, particularly those concerning travel time savings, productivity gains, and multiplier effects. The consistency of these overwhelmingly positive findings, emanating from an organization funded explicitly for advocacy, raises legitimate questions about analytical bias or the pervasive influence of the funder’s objectives on the research design and interpretation.2
Amtrak Data and Oversight
Any analysis, regardless of its sophistication, is only as reliable as the data upon which it is built. Evaluating the objectivity of RPA’s Gateway research, particularly when potentially drawing on inputs or assumptions from Amtrak, requires confronting persistent, well-documented criticisms of Amtrak’s own internal data systems.
Amtrak’s system for tracking performance and costs, known as Amtrak Performance Tracking (APT), has been the subject of scathing critiques for years from independent passenger advocates and government oversight bodies alike. The Rail Passengers Association (distinct from RPA) has labeled APT “catastrophically flawed” and “unreliable and deceptive,” arguing it fundamentally misrepresents the true economics of Amtrak’s operations.7
Specific, long-standing flaws identified include:
- Allocated vs. Avoidable Costs: APT primarily reports costs allocated across the entire system using various formulas, rather than focusing on the avoidable or incremental costs that truly reflect the economic impact of adding or removing a service. This obscures the actual profitability or cost of individual routes.
- Missing Capital Costs: APT fails to include the cost of capital consumption (depreciation and asset renewal) as an operating expense in its route performance reports. This omission allows Amtrak to claim operating “profits” for segments like the Northeast Corridor that, when accounting for necessary capital reinvestment, may not be financially self-sustaining.
- Data Imprecision: APT relies heavily on estimation rather than direct cost assignment. In the past, up to 80% of costs were allocated rather than directly measured, leading to compounded errors—a classic “Garbage In, Garbage Out” scenario.8
- Flawed Allocation Logic: Station costs, for example, have been allocated based on proxies like physical size or the number of trains rather than actual passenger volume.
- Lack of Internal Confidence: Tellingly, Amtrak’s own managers have reportedly bypassed the APT system for critical decision-making, preferring to rely on raw data from the financial accounting system—suggesting a lack of trust even within the organization that developed it.7
These criticisms are not confined to advocacy groups. Government oversight bodies have echoed these concerns. The Government Accountability Office (GAO) highlighted Amtrak’s unreliable financial reporting and limited cost data hindering efficiency analysis as far back as 2005.9 The Amtrak Office of Inspector General (OIG) itself noted in 2017 that APT’s avoidable cost methodology had “significant limitations,” lacked economic justification, and was not fully implemented.8
This history of data system deficiencies at Amtrak casts a long shadow over any research drawing on potentially Amtrak-provided information. If the funder struggles with basic data integrity and transparency in its own operations, then analyses funded by that entity, particularly those used to justify massive capital investments, must be rigorously scrutinized. It strains credulity to assume that an external advocacy partner, funded for a specific outcome, would be granted access to more accurate or unbiased data than government auditors or Amtrak’s own internal decision-makers.
This confluence of factors—a funder with documented data reliability issues providing significant resources explicitly for advocacy-aligned research—creates a significant risk of unreliable and biased outputs. When data foundations are shaky and the research house is built by the same party seeking approval, public confidence inevitably erodes.
Unexplored Alternatives and Critiques
A truly comprehensive assessment of Penn Station’s future must consider a range of potential solutions, not just the one currently favored and promoted. Yet, alternative operational paradigms, particularly through-running, seem to have been consistently downplayed in the discourse dominated by the Gateway Program’s focus on physical expansion.
Through-running involves operating regional rail services so trains continue through Penn Station to destinations on the opposite side of Manhattan, rather than terminating there. This model, a standard practice in high-capacity urban rail networks globally—think Paris’s RER A or London’s Thameslink, capable of handling dramatically more trains per hour—can dramatically increase station throughput on existing tracks by slashing train dwell times and eliminating time-consuming, capacity-intensive maneuvers like engine swaps and yard movements. Proponents argue this approach unlocks far greater operational efficiency than simply building more stub-end tracks, potentially doubling or tripling effective capacity on existing infrastructure.
Analysts like Alon Levy, known for sharp critiques of North American transit practices, have consistently advocated for through-running as a superior operational model for Penn Station. Levy contends that the extremely high costs projected for Penn Station improvements are exacerbated by a reluctance to embrace operational efficiencies common elsewhere. He has observed that RPA seemed more open to exploring through-running concepts approximately a decade ago, prior to the current intensified focus on the Gateway Program and the associated Amtrak funding.10 This perceived shift raises questions about whether the advocacy mandate influenced the thoroughness and impartiality of the evaluation of operational alternatives versus physical expansion.
While RPA has commissioned studies examining through-running, these analyses have often highlighted significant technical and operational hurdles, such as integrating disparate signaling systems and managing complex operational flows. These studies tend to frame comprehensive through-running as prohibitively complex, disruptive, and costly to implement, effectively reinforcing the narrative that the current Gateway plan—focused on new tunnels and expanding the existing terminal model—is the most feasible path.
Ben Kabak, analyzing New York transit issues, has also noted the historical context, pointing out that the canceled ARC tunnel project, Gateway’s predecessor, offered specific benefits for New Jersey commuters, including a one-seat ride for certain lines, that are not included in the current Gateway plan. This underscores that the current Gateway configuration represents a specific set of priorities and trade-offs, not necessarily the only or most beneficial outcome for all users, and that the focus on this particular path may overshadow alternatives that could deliver different or more widespread regional benefits.
The consistent prioritization of the current Gateway configuration by both Amtrak and RPA, coupled with the financial relationship and the critiques suggesting alternative operational efficiencies have been understated, invites scrutiny. It suggests that the advocacy mandate may have influenced the analytical framing, potentially leading to a less-than-objective assessment of whether operational reforms could deliver comparable or superior benefits at a lower lifecycle cost compared to solely focusing on expanding the existing terminal model. What’s overlooked is the possibility that a different operational strategy could fundamentally alter the infrastructure required, potentially unlocking a more efficient and cost-effective path forward.
The Imperative for Independent Analysis
The future of Penn Station hinges on making sound decisions about monumental public investments. The Gateway Program represents a crucial step in addressing critical infrastructure needs, yet the public debate surrounding its necessity and optimal configuration has been significantly shaped by advocacy efforts, notably those of the Regional Plan Association, explicitly funded by Amtrak, a primary beneficiary. This analysis has underscored the inherent conflict of interest arising from this funding relationship and its potential impact on the objectivity of RPA’s research outputs. The consistent alignment of reports with advocacy goals, the lack of full methodological transparency, and the context of Amtrak’s own data integrity challenges raise serious questions about the evidence base guiding decisions of immense consequence. Independent critiques further highlight concerns that potentially more efficient operational alternatives have been sidelined in this narrative.
This situation is not unique to Penn Station, but it serves as a potent case study in the challenges of evaluating infrastructure megaprojects objectively. When project proponents fund research and advocacy for their own initiatives, the line between independent analysis and promotional material blurs, risking the erosion of public trust and hindering informed debate about the most effective use of scarce public resources.
To navigate this complex terrain responsibly and ensure that the billions invested yield the greatest possible public good, we must demand a higher standard of analytical independence and transparency.
Recommendations:
For Decision-makers (Congress, DOT, State/Local Officials):
- Require full public disclosure of methodologies, data, assumptions, and models for any analysis used to justify major public infrastructure investments, enabling independent review and critique.
- Commission and adequately fund truly independent, third-party technical reviews and cost-benefit analyses of megaprojects and their alternatives, conducted by entities demonstrably free from financial conflicts of interest.
- Exercise significant skepticism when evaluating analyses funded by entities with a direct financial or operational stake in a project’s approval, especially when advocacy is an explicit component of the funding.
For Funding Entities (Amtrak, other project proponents):
- Separate funding for objective research from funding for advocacy or promotional activities. Structure research grants to prioritize and protect analytical independence.
- Improve internal data systems to ensure that any data provided for external analysis is reliable, accurate, and transparently defined.
- Enforce grantee transparency by requiring public release of detailed methodologies and, where feasible, underlying data.
For Non-Profits/Advocacy Organizations (RPA and similar groups):
- Strengthen conflict of interest management beyond simple disclosure; implement robust internal processes to actively identify, assess, and manage potential biases from funding relationships with project proponents.3
- Commit to methodological openness, proactively publishing detailed methodologies, assumptions, and data for all research reports to facilitate external scrutiny.
- Maintain clear distinctions between publications intended as objective research and materials designed for advocacy. Research informing policy should meet rigorous standards of transparency and, where possible, peer review.
- Diversify funding streams to reduce reliance on single stakeholders, thereby bolstering institutional independence and perceived objectivity.
Decisions about infrastructure of this scale must be rooted in objective reality, not shaped by funded narratives. Without uncompromised analysis, we risk spending billions to entrench yesterday’s operating model instead of building tomorrow’s network. Ensuring analytical independence is not a bureaucratic formality; it is essential for responsible stewardship of public resources and realizing the full potential of our regional rail network.
Footnotes
- Regional Plan Association, Form 990 tax filings, 2022 and 2023. All quotations in this section are drawn directly from RPA’s own tax filings describing the Build Gateway Now coalition and its funding relationship with Amtrak. ↩ ↩2 ↩3↩4 ↩5 ↩6 ↩7
- Regional Plan Association, “The Economic Promise of the Gateway Program,” April 2025. ↩ ↩2 ↩3
- See, e.g., IRS guidelines on conflict of interest for non-profits; Independent Sector principles on conflict of interest. ↩↩2 ↩3
- Regional Plan Association, “A Preventable Crisis: The Economic and Human Costs of a Hudson River Rail Tunnel Shutdown,” February 2019. ↩ ↩2
- Regional Plan Association, “Findings and Methodology for Assessment of a Hudson River Tunnel Shutdown,”February 2019. Citing extrapolation from RPA “The ARC Effect” (2010) study. ↩ ↩2
- Regional Plan Association, “Findings and Methodology for Assessment of a Hudson River Tunnel Shutdown,”February 2019. ↩
- Rail Passengers Association, reports and statements on Amtrak Performance Tracking (APT). ↩ ↩2
- Amtrak Office of Inspector General, 2017 report on APT avoidable cost methodology limitations. ↩ ↩2
- Government Accountability Office, reports on Amtrak’s financial reporting and cost data limitations. ↩
- Alon Levy, analyses and commentary on Pedestrian Observations blog. ↩
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