Federal Railroad Administration
1200 New Jersey Ave, SE
Washington DC 20590
July 2, 2024
Subject: Comments Fourth 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 fourth 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 enabling the creation of a foundation for more expansive stakeholder collaboration and detailed route planning. The study also addressed key legislative criteria in outlining the broad needs, challenges, and opportunities of the proposed Network of Preferred Routes. The comprehensive development and application of passenger-related capital costs and operating and maintenance costs is to be commended.
There is one data definition issue that needs to be highlighted to readers to avoid confusion. On each of the route slides that outline Equity and Accessibility it should be footnoted that the numbers shown in each category for Population Served, Rural Population, Rural Population in areas of Persistent Poverty, Rural Population that is Transportation Disadvantaged, Rural Population that is Health Disadvantaged, and Population in Tribal Lands, are not additive. Many individuals will be in one or more of these categories.
To initiate a new rail route four investment pillars, need to be in place – passenger related capital investment, equipment, freight railroad capacity investment and funding for operations. Without any of these four pillars operations cannot begin and unless the issue of coordinated roll-out is addressed, there is a risk of stranded assets spread among several potential routes. To mitigate this risk, it is recommended that an additional step be added to the FRA Project Lifecycle Stages (slide 26). After Final Design is completed and approved, a Full Funding Agreement should be entered into to ensure there is a defined path to fund all the investment pillars required for a route to operate.
In addition, as part of the Project Lifecycle Stages, the FRA may want to help mitigate the route complexity issues noted on slide 173. For routes that scored high on the Level of Complexity metric and traverse a high number of states, the FRA should undertake a focused outreach to stakeholders to directly guide and assist those stakeholders with the Corridor ID and Interstate Passenger Rail Compact planning and application process. This would help the least experienced route stakeholders coordinate among multiple stakeholders and move the planning forward.
As was noted above, equipment availability is one of the critical pillars required for the start of service. Amtrak currently has a procurement for a new long-distance fleet underway. However, comparing the timeline and delivery of the Amtrak procurement and the implementation timeline for new long-distance routes (slide 182), there appears to be a gap between the end of Amtrak deliveries and the need for equipment for new routes. Historically, the building of rail passenger equipment has been cyclical and does it lend itself to small batch orders. This creates an implementation risk. Thus, it is critical that car builder assembly lines, skilled employee base and suppler chain be maintained. This is an industrial policy issue as much as it is an equipment availability issue. To address this gap and mitigate the risk of a car builder and supplier shutdown, the FRA and Amtrak should explore exercising a 100-car option in order to maintain the industrial base. This initial new equipment pool does not risk becoming a stranded asset. It does double duty. It provides a ready supply of cars for any route expansion and is available to “backfill” Amtrak’s long-distance fleet to replace inevitable early retirements of some long-distance cars due to severe derailment damage.
Cost contingency needs further discussion in the study, or its application could lead to skewed conclusions. The concept, while simple, is potentially confusing to the average reader. The application of a cost contingency (slide 54) is an attempt to derisk the project estimates by more correctly estimating in Dollar terms the cost of a project. This is especially critical for initiatives like rail projects that take decades of planning before moving to construction. While some of the cost escalation is due to scope changes as a result of more detailed planning, much of the cost escalation is due to construction cost inflation. The issue is the public perception when projects are presented in the planning process where the value of current Dollars is known and compared to year of expenditure Dollars whose value is unknown. Capital expenditures should be listed first as baseline costs expressed in 2025 Dollars and then with the added cost contingency of 35% listed in year of expenditure Dollars, thus highlighting the changed value of the Dollar due to inflation. In addition to the baseline contingency there is a second cost contingency of 30% to account for unforeseen circumstances. Perhaps the definition of this second contingency could expand to account for unforeseen circumstances and provide an order of magnitude proxy for freight rail capacity
projects.
Reviewing slides 56 and 57 (overview of equipment requirements) the study appears to forecast the need for significantly more equipment than would normally be required. Looking at the table on slide 57, authors have assumed the need for more sets of equipment for each route than Amtrak currently operates or has operated historically. While there is a need for some terminal based “protect” equipment, those cars serve to protect multiple routes. There is not one “protect’ trainset for each route. Referring to slide 56 last bullet which notes the requirement for 25% spare cars above and beyond the “protect” trainsets noted on slide 57. A 25% (or more) spare cars ratio is normally associated with the additional car requirements needed as a result of issues around maintaining a 40-year-old fleet and an active overhaul program. The equipment fleet for the proposed new long-distance routes will be new and as part of Amtrak’s long-distance fleet procurement they will be transitioning to manufacturer predictive trainset maintenance. Predictive trainset maintenance is designed to generate a transformative increase in fleet utilization and productivity resulting in lower fleet requirements. Shouldn’t this be reflected in estimates of the study’s equipment requirements and costs?
Listed on the slides describing each of the Preferred Routes is an estimate of passenger related capital costs for station and maintenance facilities. While slide 55 notes that new routes would share existing network maintenance facilities (with some additional assets), there is no discussion that new routes could share maintenance facilities among themselves at new endpoint cities. It appears that each new route will construct a maintenance facility instead of constructing a shared facility. Another factor that needs review is the cost of additional yard tracks required at existing and new maintenance facilities simply to store unproductive equipment that is the result of the poor capital asset utilization noted in the prior paragraph.
In order to assist stakeholders in their planning process it is critical that the Long-Distance Service Study Final Report include important data details used to determine the route-level summaries. The prioritized list of passenger-related capital projects (slide 23) should be compiled not only by project type but in a manner that will allow stakeholders to summarize all passenger related project’s capital costs by route segment. Certain route segments clearly have higher investment needs (Class 3 to Class 4 track) driving significant capital costs. This segmentation of data would facilitate stakeholders in identifying a combination of route segments where initial service could begin at a much lower capital cost. Similarly, a breakdown of metric ratings (slides 177 and 178) by categories would allow stakeholders to identify those metric categories driving the overall route rating as shown on slide 178.
A major shortcoming of the Long-Distance Service Study as an actionable analysis is the absence of any type of monetized Benefit Analysis. It is a cost study only, no ridership estimate is provided, even at a high level. There is no estimate of ticket revenue to compare with operating costs. Most critically there is no estimate of the direct and indirect economic impact of visitor travel enabled by the new train route. This study shortcoming exists even though the study compiled the key parameters required for a high-level Benefits estimate – population served, general income of that population, overall travel demand from the 2022 Next-Generation National Household Travel Survey National Passenger Origin-Destination Data, the frequency and approximate rail travel time for each of the proposed routes, long-distance average fares and long-distance mode share from Amtrak’s data and Market Research. Without a monetized Benefit Analysis stakeholders do not have any method, even at a very high-level, to weigh the value of moving forward into the Corridor ID process. Rail Passengers Association has a benefits calculation tool that can be used to provide a complete
actionable study for stakeholders.
The Rail Passenger Association of California and Nevada fully supports any FRA initiative for a recurring long-distance planning process. RailPAC also supports the concept of establishing a Long-Distance Public Committee to focus on current and new Amtrak long-distance services. Both of these initiatives could also serve to address any issues that might arise in the implementation of new long-distance services.
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