Comments on the CalTrain Downtown Extension DEIR/DEIS

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CalTrain downtown SF extension | Electrification of CalTrain

May 9,1997

Ms. Marie Pang, Environmental manager
Peninsula Corridor Joint Powers Board
1250 San Carlos Avenue
P.O. Box 3006
San Carlos, CA 94070-1306

Dear Ms. Pang,

Peninsula Rail 2000 requests that the JPB adopt the present Draft EIR/EIS and develop a Final EIR/EIS. We also urge near-term completion of system-wide electrification, especially if the downtown extension must be phased or postponed.

We believe that the JPB and other concerned agencies have been making pessimistic assumptions about prospects for funding and political support for the downtown extension. We are convinced that political support for this project could be greatly strengthened (in view of the vast benefits of this extension and upgrade of the CalTrain system) compared to far fewer benefits at greater cost for the BART Colma-to-Millbrae extension. With political support, most of the funding problems would disappear.

We believe that an extension into downtown San Francisco will add far more than the 4500 new riders suggested by the ridership model. Results of CalTrain ridership modeling were highly constrained by unfair assumptions of limited CalTrain service frequencies and parking at stations. We request that these studies be redone with the faulty assumptions rectified.

San Francisco is a world-class city and deserves a world-class transit center where all regional carriers would connect. CalTrain and future high speed rail should terminate in a world-class transit center--not Fourth and Townsend. Despite the revival of the 4th and Townsend neighborhood, the Market Street area will be the primary destination of regional passengers for decades to come.

In response to the questions on the options for a Final EIR/EIS, PR2000 recommends the following:

1. Townsend Street alignment:

Townsend/south side

Because of less construction, lower cost and obstruction to side streets.

It is not in the middle of the street like Townsend center which puts vehicular traffic on both sides of the station. Townsend south has a better station to serve crowds returning from the stadium because it has 3 tracks--one or more of which can hold waiting trains. Townsend south also has one less grade crossing than Townsend Center. The long tunnel along Townsend with a portal at 7th is very expensive, and essentially eliminates the possibility of a Townsend station for serving Mission Bay and the new stadium.

2. Mined tunnel alignment

Long radius

Because of lower cost, shorter tunnel and higher speeds through the tunnel.

The long radius, short tunnel has the lowest cost and the highest operating speed (40 mph vs. 20-30 mph for the other 2 alternatives). The long radius tunnel also results in the least excavation volume and hence the least truck traffic during construction. Also, a long radius will not have the wheel-squeal which results from wheel scraping against rails on a short radius track.

3. Transbay bus terminal location

B--Transbay Short & Medium

We prefer the tightest coupling of the bus and rail terminal possible.

We also want to see the alternative with the maximum potential and suitability for joint development and retail. PR2000 has long supported the co-location of the bus and rail terminals for these reasons.

4. Storage yard location

7th and Townsend

We prefer this location because it offers lower operating costs due to the yard being double ended and somewhat closer to the downtown terminal (making the deadhead runs between yard and terminal shorter).

JPB has a permanent easement to run trains on the site of this yard, and this site is currently occupied by JPB tracks. The other site--under 280--would not allow for a double-ended yard (trains would have to enter and exit from one end only) and interferes somewhat with plans for a Muni yard.

5. Propulsion system

Full electrification, 25 KV AC

Because this provides for system-wide improvements, higher speeds, quieter trains, and lower costs.

The operating cost estimates do not include reduced power costs from regenerative braking or the recent PUC deregulation of electrical power providers that could be as much as 40% lower costs than used in this study.

If dual mode is selected, we strongly recommend that 25 KV AC be used, so that power infrastructure would be compatible with high speed rail.

The fully electrified system has enormous benefits (increased speed, reduced running times, dramatically reduced noise and air pollution, reduced operating cost, increased reliability) over the dual mode proposal. Since the present locomotives must be replaced by the year 2005, why are they included as part of the cost of the downtown extension?

Electrification should be fast-tracked
If for any reason, the downtown extension must be phased or postponed, Peninsula Rail 2000 urges that system-wide electrification be made the top priority and considered for immediate implementation. It will do more to bring CalTrain into the age of modern, efficient high speed transportation than any other major capital improvement. It will make the downtown project attractive to people in downtown San Francisco who picture CalTrain's noisy, polluting, diesel locomotives. Electric propulsion is mandatory for any downtown extension involving an underground terminal. Because it accounts for 20% to 30% of the project costs, system-wide electrification will make any future attempts towards the extension far more affordable.

Ridership predictions are highly suspect
We have serious concerns about the DEIR/DEIS/S ridership modeling. Why were only two very limiting and anemic schedules, 60 and 86 trains, modeled for this half-billion-dollar project? Why wasn't the CalTrain downtown extension modeled with a 208-train schedule--the current frequency of BART at the Colma station? Or, why wasn't the BART-to-SFO/Millbrae extension modeled with a 60-train schedule--the current CalTrain schedule? The maximum operating scenario modeled is only 86 trains, a mere 10 round trips more than this July's still-anemic 66-train schedule. Is there any surprise that assumed ridership gains from the downtown extension are so modest?

One has to question the credibility of modeling which shows no ridership differences or effects between a 60- or an 86-train schedule at numerous stations on the CalTrain line. Furthermore, the model suggests that there is no ridership effect between build and no-build at stations south of San Jose on the Gilroy extension.

An additional flaw in the models concerns parking at stations. BART plans to provide 7,500 free parking spaces at Colma, South San Francisco, San Bruno and Millbrae stations. This exceeds the 5,103 (current) and 6,934 (planned for 2010) spaces at ALL 22 CalTrain stations from South San Francisco through Tamien considered in the DEIR/DEIS/S. While PR2000 does not advocate large, obtrusive free parking facilities at train stations, no valid comparison is possible without assuming comparable station parking scenarios.

We suspect that the models used were weighted to favor high frequency and bountiful parking. We infer that this is why the model showed no ridership difference between a 60-train or an 86-train schedule at mid-line stations such as Belmont. This suggests that the model assumes that additional frequency yields no additional ridership if the parking is already full. This also implies that walk-up, drop-off, bike-to-train and bus-to-train ridership was ignored by the model. If this is the case, we feel that these assumptions are gross errors, and the ridership modeling must be redone.

We request that the JPB hire an "out-of-area" consultant to evaluate the ridership figures for the downtown extension. The FTA uses Charles River Associates of Boston for most of the FTA projects. We advise that the JPB hire Charles River Associates to estimate the number of riders that would use CalTrain if it were to be extended into downtown San Francisco.

Costs overestimated
We believe that electrification capital costs are probably $40 million less than stated in the DEIR/DEIS/S. For example, the DEIR/DEIS/S states that the present locomotive fleet is due for replacement around the time the downtown extension would be built. This cost would therefore be incurred in the no build alternative, but not in any of the build alternatives. In view of these considerations, this locomotive replacement cost should be subtracted from each of the three propulsion mode choices. In addition, we believe that $15 million can be saved by purchase of three fewer locomotives because only 20 would be necessary for an 86-train schedule. We also believe that signaling upgrade costs are overestimated by $10 million and that electric power costs are overestimated by 40% to 50%. We cite additional likely cost overestimates for electrification in the appendix at the end of this letter.

The fundamental purpose of upgrading CalTrain is to provide an alternative to the automobile, not to bow to political pressures that undermine this goal. We are counting on the JPB support for this project--central to our only chance for a modern, efficient alternative to the congested highways of the Peninsula corridor for the next 30 years. Our organization and our affiliates are very frustrated that BART is capable of using politics rather than efficiency and cost-effectiveness as de-facto criteria for public transit.

In the coming years we expect to see increased awareness of the greater benefits of the downtown extension along with the full upgrade of the 77-mile CalTrain system--at no more cost, possibly even less--than extending BART a mere eight miles to SFO/Millbrae. We are convinced that the fact of this comparison has plagued efforts to secure funding for the latter project. We believe that true political support for CalTrain can become reality and would hold greater promise for regional mobility. We have also seen progress with plans to bring high speed rail to downtown San Francisco using the same extension. In view of these developments, killing this project could prove to be an untimely, monumental blunder.

PR2000 is convinced that, with greater awareness of the merits of CalTrain, and a vocal champion from San Francisco, the downtown extension and a multi-modal transit center will happen!

Adrian Brandt,
President, Peninsula Rail 2000

Additional Comments about Full Electrification

PR2000 believes that the analysis and comparison of the propulsion mode capital and operating costs are in need of further clarification. For example, the difference in cost for 86 trains between the no build and the build options under the "Timetables & Tickets" item is $700,000. Furthermore the analysis of propulsion includes the description of public address systems and communication systems that do not relate to propulsion mode. The operation costs include more than 40% of its costs to a category of "Other." If it is not "Labor," "Materials" or "Services" then "Other" needs greater explanation.

Number of Locomotives
The capital costs for electrification include the amount for 23 electric locomotives and the same number of diesels or dual-mode. One of the main advantages of electrics are their reliability and power such that not as many electric units are required to provide the same level of trainsets to cover for identical frequencies. Twenty electric locomotives could easily handle the proposed 86 train schedule. Capital costs should be reduced by $15 million for a proper number of locomotives.

Contingency costs?
We also believe it to be inaccurate to apply contingency costs to locomotive procurement. Since these costs are known from present day practice and offer little uncertainty in the world market level. This also reduces the capital costs by $15 million.

Overestimate on signaling
The amount attributed to modifying the signaling system so as to accommodate electric currents in the rail is $20 million. At the industry average of $160,000 per crossing, that is enough to fully replace 125 grade crossings! There are only 56 crossings from Gilroy to San Francisco. For the purposes of this project, some of the electronics may need to be enhanced, but certainly not $20 million worth--half that amount at the very most.

Number of substations
The DEIR/DEIS should take into consideration additional reductions due to current upgrades for grade separation projects and relocation of track for the BART/SFO extension. Relocation of the power substations approximately 5 miles south of the proposed locations would eliminate the need for the one at the San Francisco end of the line. This is a savings of $2.5 million directly. By relocating the substations, CalTrain could have access to the reduced cost of power that municipal power companies in Santa Clara and Palo Alto provide and would eliminate the costs of a 1 mile conduit in San Francisco. No consideration of combining substations with the BART/SFO stations appears, yet ridership numbers include the BART/SFO project as being in place. Since BART receives discounted power (40% less) and the combined substations would reduce costs, these reductions need to be included in this analysis.

Total capital overestimate may be $40 million
The combined savings of these items reduces the total cost by $40 million. Since new locomotives will be required at the end of life of the existing fleet, the real costs are the construction and management cost of about $125 million. One major aspect of these costs that this study overlooks is the length of time that these improvements will be in affect. Catenary and power structures on the east coast have been in place for 60 years.

Potential power costs savings
It is important to assess if the operating cost reductions recover the capital investment. The DEIR/DEIS states that the savings per year is nearly $1 million. In addition to including a significant amount of unaccountable items in the analysis this study completely ignores recent deregulation of the power industry and access to reduced power costs from municipal sources. Amtrak and BART both have announced purchases of power that are 40-50% lower than the regulated rates used in the DEIR/DEIS. Acceptance of a 35% reduction in the DEIR/DEIS power costs allow a yearly savings of nearly $3 million. In the 30 year life of locomotives, that yearly savings would recover about $90 million.

Potential savings on track maintenance
In addition, electric locomotives are 35 tons lighter than dual mode or diesels. This translates into a reduction in trackage maintenance costs which are not described in the DEIR/DEIS analysis.

Savings to the community?
If we were allowed to consider air and noise pollution savings along the corridor then the electrification would easily recover its capital costs. Additional considerations should also include some value for the improved on-time performance and image of modernity that electrification would allow. Neither of these factors are quantifiable but would increase ridership potential in a way that no other improvements can.

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Last updated: May 11, 1997

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