Ladies and Gentlemen:
Peninsula Rail 2000 hereby submits on behalf of its members the following comments regarding the "DRAFT Assessment of Electrically Powered Rolling Stock Equipment" dated August 2000, hereafter referred to as "the report." Also, "Caltrain" is hereafter understood to mean the Caltrain staff, consultants and the Peninsula Corridor Joint Powers Board.
In Peninsula Rail 2000's view, the most important point to be considered in selecting electric rolling stock is that Caltrain should not be making detailed decisions about rolling stock, beyond the requirement that it be powered by 25 kV AC overhead and meet or exceed certain other key requirements (end-to-end run times, acceleration and braking rates, operating speed, interior and exterior noise levels, ride quality, loading rates, platform configuration compatibility, etc.).
It should be up to bidders to decide what rolling stock they wish to offer to Caltrain in response to a performance-based specification. Peninsula Rail 2000 believes that Caltrain's demonstrated track record of specifying new equipment in great detail will almost certainly not lead to the best solution the market has to offer. The market knows best, and Caltrain should allow the market to speak for itself without unduly constraining the options (EMUs vs. locomotives) before bidding even begins.
Caltrain should give further serious consideration to the option of Electric Multiple Units (EMUs), and should recognize that they offer significant advantages over the use of electric locomotives. At the system level, these advantages far outweigh the additional cost and difficulty of procuring and operating a new EMU design. The advantages of modern EMUs include, at the very least:
In view of the combined cost of the Rapid Rail improvement project, full system electrification and "Baby Bullet" triple tracking (close to $1 billion total), the extra $15M acquisition cost + $4M/year operating cost of an EMU fleet (simply quoting the report's cost figures, for an extra $55M over 10 years, or 5% additional overall investment) seems like a relatively small price to pay for the enormous operational and service advantages of EMUs.
Caltrain should request "Design, Build, Operate and Maintain" (DBOM) bids. This would let the market reflect the true cost differentials of locomotives vs. modern EMUs. The report draws its conclusions based on cost figures for the old Northern Illinois EMUs. In contrast, modern IGBT-powered EMUs, now common on the world market, would incur much lower maintenance expenses.
Caltrain should stay open to new rolling stock designs. The field of potential suppliers for FRA pre-certified rolling stock is narrowing with Bombardier's recent acquisition of Adtranz. To preserve the competitive nature of the bidding process, the field should be opened to all entrants, including those who might propose new variations of existing rolling stock solutions suitably adapted to Caltrain's needs. The report unfairly applies a double standard in favor of the ALP-46 locomotive, treating it as a proven design when in fact this locomotive is currently neither available in the United States nor approved by the FRA. If New Jersey Transit can take the risk of procuring a German locomotive design yet to be adapted for US conditions, then Caltrain should not shy away from procuring any of a number of European or Japanese off-the-shelf EMU or locomotive designs, suitably adapted for FRA regulations. This is not a "radical new idea" as implied by the report.
The report appears to underestimate the price of New Jersey Transit's new and unproven ALP-46 locomotives, variously quoted as $4.2M or $4.5M per locomotive. The February 2000 issue of the trade magazine Railway Age reported the value of the NJT contract at $123.4M for 20 locomotives, with an option for 4 more locomotives not included in the cost. This leads to a price of $6.2M per locomotive, or nearly 50% more than quoted in the report and comparable to the Amtrak/MARC HHP-8 from Bombardier. It is unlikely that this cost would come down simply because Bombardier will enjoy an effective monopoly over FRA-compliant electric locomotives. In the report, the $6.2M figure would actually tilt the acquisition cost in favor of EMUs.
Peninsula Rail 2000 reiterates its strong support for Caltrain electrification, and hopes that Caltrain will take this once-in-a-generation opportunity to choose the most effective rolling stock solution that can offer the most improvement in service along the Peninsula Corridor. Caltrain would do a disservice to the public by ignoring the overall problem of system performance, and instead considering only the very narrow question of "what is the cheapest way to buy electric locomotives?" rather than the wider one of "what is the most effective way to improve transportation in the Caltrain corridor in conjunction with system electrification?" An open procurement process unfettered by prejudice against EMUs would be a bold and visionary step in the right direction.
President, Peninsula Rail 2000