August 19, 2023
USDOT: Pete Buttigieg (Cabinet Secretary)
FRA: Amit Bose, Administrator
FTA: Nuria Fernandez, Administrator
To: contactus@fralongdistancerailstudy.org
Subject: Comment letter on Round 2 on FRA Long-Distance Service Study
The Federal Railroad Administration has twice this year asked for input regarding passenger rail in the United States. As a nationally recognized rail passenger advocacy organization, RUN answered the request for public comment on the Federal Railroad Administration’s Amtrak Daily Long-Distance Service Study.
This is a follow up to our March 13, 2023 comment letter on the FRA Long Distance study, which included our recommendations for an enhanced passenger rail system with additional routes and services. We now respond to the second call for additional input to the Conceptual Enhanced Network which the FRA has proposed based upon input received thus far.
To reiterate and clarify our position, RUN advocates on behalf of all riders on rail-based transportation, whether Amtrak or local rail transit. We appreciate the importance of Amtrak in providing mobility throughout most of the nation, and we also advocate for improved connectivity between Amtrak and local rail transit.
Members of RUN have studied the report developed by the FRA which has explained the methodology used to develop the enhanced network, and deeply appreciate the legislative considerations guiding that planned development. Hopefully this effort will not only enhance connectivity between major cities and regions and will also connect rural and/or less advantaged communities between those cities and within those regions. Enhanced and expanded routes will result in a true system of interconnected passenger rail routes producing increase ridership as well as developing and increasing local and state economies.
Enhanced Network:
For the maximum public benefit of this Long Distance Study, we need the FRA to champion the expansion and improvement of the Amtrak long distance network, after the conclusion of this study process.
We ask that the FRA prioritize several projects to serve as test cases to prove the merits of this enhanced system. For the credibility of FRA and Amtrak, we need some near-term wins of “low-hanging fruit” routes that would require minimal new infrastructure. It could be a new route or an improved current route, but improvements needed should be accomplished to demonstrate the effectiveness of enhancements to passenger rail. We suggest the following restorations of service:
· Daily service on the Cardinal and Sunset Limited
· The Desert Wind from Salt Lake City to Los Angeles (with perhaps initial service SLC- Las Vegas)
· The Pioneer from Seattle and Portland to Salt Lake City via Idaho
· A new route from Meridian, MS to Dallas/Fort Worth, Texas
· The Floridian directly connecting the upper Midwest to Florida via Atlanta
· The Broadway Limited from New York to Chicago
· The North Coast Hiawatha from Seattle through southern Montana’s major cities to Chicago
· The Rocky Mountain Flyer, connecting El Paso, Albuquerque, Denver, Casper and Helena, MT to Shelby, MT.
Our proposals, if implemented, will allow for this enhanced network carrying many more travelers to many more destinations to become even more successful.
Following the ‘conceptual-level identification of capacity improvements’ in this Long-Distance study, the FRA needs to subsequently work with host railroads and others on more in-depth engineering studies to itemize and provide cost estimates on infrastructure capital projects needed along each of the proposed new/enhanced/restored corridors. The current study should recommend a path forward for this work to begin as soon as possible.
Also worthy of investigation are new policy incentives for host railroad capacity improvement projects
Economic and Social Well-Being of Rural Areas, Rural Accessibility:
We are very pleased to see that the study will prioritize rural and disadvantaged communities not served by existing passenger rail network, including tribal lands.
There are also many urban, suburban and rural residents alike who do not “choose” to live without personally driving their own car. They might be too young or too old to drive, have a disability that does not allow them to drive, or they might not be able to afford to buy, insure and maintain a car. The concept of “Universal Basic Mobility” is gaining popularity. It is idea that all citizens should have a decent range of affordable transport options, regardless of their socioeconomic status, disabilities, or geographic location.
An expanded nationwide system of regional and intercity passenger rail coordinated with local public transit would enable more urban and rural low-income families to access health care, education, jobs, and community life. It is also true for youth, elders and the disabled who neither can afford a car or no longer want to drive. Expansion of passenger rail service would also improve transportation access and help support local economies in rural communities, cities, suburbs, and Native American reservations.
As part of this study, FRA needs to measure both the public and economic benefits of Long Distance trains, including quantifying (in dollars) both direct and indirect benefits to local economies.
Measures of Effectiveness and Benefits:
Transportation safety benefits of Long Distance trains-
One important benefit to rural travelers provided by the Amtrak long-distance trains is a safer alternative to driving. Rural residents make up less than 20% of the U.S. population, but account for about half of the total number of traffic fatalities nationwide, due to higher per-capita miles driven (or being a passenger in car for more miles).
The FRA study should estimate the safety benefits (reduced car accidents) of existing and new Amtrak Long Distance train services.
Environmental and energy efficiency benefits of Long Distance trains-
The FRA study should estimate the environmental benefits (estimates of reduced pollution, fuel consumption compared to driving) of existing and new Amtrak Long Distance train services. Particularly important is estimation of the reduction of greenhouse gas emissions enabled by Amtrak long-distance train services- both new and existing.
Equipment:
An essential step for improving Amtrak long distance service is the acquisition of new equipment: there are currently not enough locomotives and passenger cars (the Superliner fleet) in a good state of repair to reliably sustain the existing Amtrak Long Distance Network.
This FRA study needs to estimate how much new equipment is needed for these routes, and how much service can be supported with refurbishment/repair of existing Long-Distance equipment not-in-service (in storage at Beech Grove yard?). FRA needs to make specific recommendations to Amtrak on procurement of new Long-Distance equipment, and help find ways to expedite this procurement.
The FRA study should also investigate maintenance requirements for new Long- Distance services, including possible locations for new Amtrak maintenance facilities.
FRA study team should engage rail advocacy groups to address passenger comfort in designs for new long-distance Amtrak equipment.
Congress has recently allocated funding to restore to service the hundreds of cars and locomotives currently out of service for maintenance/overhaul/rebuilding.
Rail passenger advocates using government information sources have concluded that several daily, on-time trains each way on a route are proven to lure and keep people riding the rails.
We propose building to this several-trains-per-day concept as new rolling stock is manufactured and put into regular service. By our estimates, approximately 10,000 new passenger cars of various configurations will be required to supply a minimum of six daily trains for each of the current routes as well as the new proposed routes. We can begin this process by making every passenger train in the US a daily service.
As a side note, this manufacturing base along with the numerous component manufacturers will provide hundreds, if not thousands of new good-paying jobs throughout the United States. These jobs will, in turn, provide for subsidiary jobs which invariably spring up around the communities in which they are located.
Crew resources:
The FRA study needs to examine needs and strategies for hiring, training and retaining crew for Long Distance trains. The Covid relief funds provided by Congress should have enabled Amtrak to maintain its existing crews, but instead it furloughed personnel. These layoffs have severely impacted Amtrak’s ability to both crew the trains as well as maintain and repair the equipment needed for the trains, as short as they currently are, to still operate.
Host railroads:
Freight train interference/on-time performance. Freight railroads have been required by law to provide Amtrak with “preference”. This law is often ignored and as a result passengers suffer as well as the American economy. Federal legislation is required to hold freight rail companies accountable and to allow Amtrak to defend its legal rights and ensure p=passengers are not unfairly delayed by freight trains. We would also like to see better co-operation between Amtrak and the host railroads to capture back some of the business which should be hauled by rail. By doing so, some of the unnecessary truck traffic which has also resulted in a driver shortage and more expensive shipping rates could be relieved.
Sincerely,
Richard Rudolph, Ph.D., Chairman, Rail Users Network 207-776-4961. rrudolph1022@gmail.com
Andrew Albert, Vice Chairman, Rail Users Network aalbertnyc1@gmail.com