Federal Railroad Administration March 6, 2024
1200 New Jersey Ave, SE
Washington DC 20590

Subject: Comments Third Meeting Regional Working Groups, FRA Long-Distance Service Study

Dear Sirs,

On behalf of the Rail Passenger Association of California and Nevada I am submitting the following comments to the third round of Long-Distance Service Study Regional Working Groups. Once again, I want to complement the FRA and the study team on their well organized, comprehensive in-depth analysis and how it addressed key legislative criteria in developing its proposed Network of Preferred Routes. The coverage and travel options offered by the proposed network are truly impressive. The addition of several north – south routes is applauded. The potential synergy and expanded matrix of city pairs of a coordinated Chicago – Miami and Detroit – New Orleans routes offers great potential for connectivity,

First, before I discuss some broader issues, there is data definition issue that needs to be highlighted to readers. On slide 60 it should be noted that the numbers for population served shown in each category, Transportation Disadvantaged, Below the Poverty Threshold and Tribal Lands, are not additive. Many individuals will be in one or more of these categories. This is also a factor on the specific route definition slides (slide 63 forward).

The implementation plan and timeline outlined on slide 154 is not encouraging. One of the factors that has been noted in comparisons between the world and the US in significant cost differences in capital projects, is the time it takes to accomplish the projects. Fifteen years of planning to operate one round-trip on an existing rail line seems particularly excessive. Given the scope and effort devoted to the Long-Distance Study and the role of local stakeholders in meeting the Corridor ID requirements, how much additional planning is required? In addition, almost all capital work required will be taking place within the existing and currently operating rail rights-of-way. Any station would likely reuse an existing structure or station site. Given these factors shouldn’t project development be relatively straightforward? The findings contained in the Long-Distance Study on routes, passenger related capital investments required, and public benefits should fulfill tasks of any project planning requirement, especially given the services use of existing rights-of-way.

If the long-distance route initiative is to succeed it is critical that the FRA and Amtrak focus on the implementation process and develop strategies to streamline the implementation. Particularly the FRA and Amtrak should provide additional staff to expeditiously review all submissions with a goal to reduce turnaround time by three-quarters. The FRA should also develop recommendations to Congress, specifically for the Long-Distance initiative, for authorizing broader categorial exclusions. Operating one additional round-trip should not require an in-depth environment study nor should “quality of life” of lineside neighbors be an issue. Both of these factors should be easily outweighed by the public benefits of service to rural areas, tribal and social justice communities.

Given the scope and effort devoted to the Long-Distance Study, there is a critical need for at least some service implementation near-term. In identifying preferred routes for near, mid and long-term implementation for stakeholder meeting 4, it is critical that the team identify near-term services and propose an aggressive implementation plan. Daily service on the Cardinal and Sunset Ltd are obvious priorities, but there may be other opportunities as well. Partial routes linked to an existing route (i.e., Salt Lake City – Las Vegas (California Zephyr thru cars). Atlanta – Ft. Worth (Crescent thru cars) or rerouting the Los Angeles section of the Texas Eagle from Ft. Worth to El Paso via Midland/Odessa are examples. Since the focus of the study was basic transportation, a coach only service with café food service could be considered as an option for some new services.

Equipment availability is a critical issue both near-term and long-term. Near term any opportunity to start new service will have to utilize the existing fleet. Thus, it is critical that the FRA and Amtrak develop an action plan and funding to keep the current fleet in a state of good repair. Also, while a new equipment order would normally mean that rebuilding of damaged cars would be constrained to those with cosmetic damage, there should be consideration to broadening these criteria somewhat especially for Superliner II and Viewliner cars.

Amtrak is currently refleeting its network. In doing so the US is once again developing a passenger rail car industrial and supplier base. Longer term, it is critical that as the Amtrak contract for new cars nears completion, the implementation timeline for routes recommended in the Long-Distance Service Study be to the point and have funding to enable the production line and supply base to continue. Otherwise, the US will be in the same position it found itself in for many years, no rail car manufacturing base.

Finally, in comparing the Proposed Network of Preferred Routes from Work Session 3 with Work Session 2 it is clear that trade-offs regarding the legislative criteria – discontinued routes, geographic coverage, rural accessibility, etc. – were made. This was based on professional rail planning experience analyzing segment route options compared to actual rail line routings. Some discontinued route segments and criteria areas were bypassed. I would expect that additional trade-offs will become apparent in the 4th Regional Working Group meetings.

With that in mind it is recommend that a second look be taken at the routing of the Dallas/Fort Worth to San Francisco Bay Area west of Phoenix. As was noted in an earlier work session, connectivity is a vital consideration in choosing rail travel. But connectivity is more than just access to the system; it is also how many destinations are available from each origin city. The routing of the DFW – Bay Area route offers a limited number of potential destinations. Routing the train via Los Angeles would enable many more connection options opening up a huge matrix of destination options, including most of those on the preferred routing suggested in the 3rd regional meeting. All the cities with new service and restored service would be retained with this revised routing. If the endpoint is required to be the SF Bay Area, the train could be operated along the Coast Line, California’s other passenger railroad.

Four factors influence this recommendation. With almost 200 miles of un-signaled class 2 and class 3 track, and 100-year-old desert wash timber trestles, the passenger related capital cost for upgrading the route west of Phoenix will be significant. Add in Positive Train Control and capital costs increase further.

In addition, while required freight capacity upgrades are not considered by the study team at this point, for stakeholders familiar with freight traffic volumes on the proposed route west of Cadiz and the impact of potential capital expenditures need to be recognized and taken into consideration. BNSF’s rail line between Dagget and Valley Jct., traveled by both BNSF and UP trains, has a very high traffic volume. The Tehachapi Pass between Mojave and Bakersfield is equally problematic with a capacity-constrained mountain rail line with a high volume of freight traffic. Both rail line segments are identified as routes for container shuttle trains from the Ports of Los Angeles and Long Beach to inland ports and transshipment hubs. Even at this early stage in the planning process this freight capacity issue needs to be recognized and incorporated into the planning process in order to avoid time-consuming challenges that will potentially undermine the Service Development Planning phase.

Another consideration should be the judicious use of public investment. As part of the overall long-distance development initiative, it is planned for Sunset Ltd. to operate via Phoenix. This involves the rebuilding of the Wellton Branch, a major capital expense. Operating the DFW – SF Bay Area route along the upgraded Wellton Branch would better utilize this investment. Further west, through Gorgonio Pass another high-volume mountain crossing, the Riverside Transportation Commission has completed a Tier I Environmental Study and is gathering funding for a Tier II Environmental Study for its Coachella Valley Corridor. The Coachella Valley Corridor has been accepted into FRA’s Corridor ID process. It is anticipated that this initiative will require substantial freight capacity investment. Routing the DFW – SF Bay Area service via Los Angeles would more fully utilize this investment and increase the public benefit of publicly funded Coachella Valley improvements.

Another factor is not only is Tehachapi Pass rail route problematic from the freight capacity standpoint, it is also parallel to the California high-speed rail network. This project has been accepted into FRA’s Corridor ID process, and the route has its environmental clearance and is ready to move to 100% design and pre-construction work. All the proposed cities in the Central Valley potentially served by DFW – SF Bay service, can be accessed through Los Angeles. Investment to facilitate a 30-mph passenger service parallel to a 200-mph passenger service does not seem to be the best public investment strategy. While outside the consideration of long-distance study, the reality of the CAHSR project, combined with the other factors noted above argue that a routing of the DFW – SR Bar Area service via Los Angeles should be discussed as part of the run-up to the 4th working group meeting.

Thank you for all the efforts undertaken with this study. The Rail Passenger Association of California and Nevada (RailPAC) is an all-volunteer statewide organization that advocates for the improvement of commuter and intercity passenger rail service.

Sincerely,

Steve Roberts, President
Rail Passenger Association of California and Nevada