Thank you for the opportunity to provide comments upon the draft EA/EIR for the much-delayed Caltrain electrification program.
Caltrain should use electrification and introduction of new rolling stock as an opportunity to radically transform and upgrade the system, much as the Transperth urban rail system did in Perth, Australia, in the early 1990s, tripling ridership.
Rather than just running the same service with the same operational problems behind a different locomotive (the "put some lipstick on that pig" scenario), Caltrain should endeavor to use the very significant capital investment represented by any electrification program to attempt to addresses at least the following important issues:
The underwhelming cost-benefit of the program as reported in the draft DEIR reflects, perhaps quite accurately, a program too narrowly construed.
The overall life-cycle costs of different equipment options should be considered in light of the issues raised above. For example, if passenger vehicle fleet replacement combined with electrification is able to deliver barrier-free boarding and improved doorways, the service improvement to average trip times may be more from level boarding alone than from electrification alone; the greatest and cheapest improvements will result from not undertaking such programs separately.
Similarly, combining an electrification program with a legislative and technical program to escape from or gain significant waivers from FRA regulation may save hundreds of millions of dollars in equipment costs and millions of dollars in annual operating costs.
Equipment costs need to be much more accurately accounted for than they are in the DEIR, especially given that at least 73 of the existing gallery cars will reach the end of their economic life in the early 2010s. A year 2020 scenario in which electric locomotives are purported to be hauling the existing gallery car fleet is simply not realistic.
Peer review should be undertaken to ensure that the "one for one replacement" procurement studied throughout the DEIR does not result in Caltrain purchasing more equipment than is needed to provide anticipated levels of service. Proper life-cycle accounting of maintenance and capital costs, and examination of operations improvements which can improve utilization of expensive capital equipment, may well result in revised rolling stock fleet sizes and lower initial capital costs for the program, or result in a different recommended equipment choice.
Electrifying a line used by fewer than a hundred trains a day is universally regarded as fiscal nonsense, with huge fixed costs far outweighing minute operational benefits. Even in the most optimistic scenarios, Caltrain service to points south of downtown San Jose will be characterized by factors such as long inter-station spacings, tidal and peaky "commuter rail"-type ridership, infrequent service, together with a very challenging right-of-way control situation.
All of these factors make the decision even more cut and dried in Caltrain's case: any money spent electrifying UPRR's (or VTA's or Caltrain's) tracks south of San Jose is money quite simply wasted, money which could be far better spent on other, net-positive Caltrain projects within Santa Clara County. This long section of line would also have disproportionately higher levels of maintenance costs associated with OCS maintenance; it would be "the gift which keeps on giving."
Follow best global practice: Don't even think about it!
Several issues are involved:
Caltrain needs to demonstrate its ability to build and operate a modern and attractive service for the residents of the San Francisco Peninsula far sooner than the present funding priorities of VTA will allow.
Given the huge borrowing costs of the DTX project, all delays in service startup are potentially catastrophically expensive, not to mention embarrassing.
By removing the fiscal and political roadblock of requiring 100% fleet replacement and 100% electrification, a significant cause of uncertainty on the critical path to DTX completion can be mitigated.
By electrifying the full San Francisco to San Jose line in two stages, with Palo Alto a fairly natural break point both operationally and jurisdictionally, Caltrain may be able to better match cash flow to construction while operating much better levels of service than are available today.
With only 60% of the rolling stock and fixed installation costs -- and assuming engineering design overheads for the entire line are borne up-front -- procurement and start-up should be able to proceed with little delay. Contract options would ensure that full system build-out could proceed if, as one might expect, there is a change in the local political winds and there is a desire to build upon success.
With a comparatively small and completely modern fleet, maintenance facility needs on the initial segment of the line will be modest -- perhaps limited to a train washer and enclosed inspection platforms -- and heavier maintenance such as wheel profiling can be scheduled at the CEMOF.
Caltrain should consider design-build, design-build-operate, design-build-maintain and other "novel" contracting arrangements for both infrastructure and, especially, for rolling stock.
Not only might such arrangements result in lower life-cycle costs to Caltrain, but builders motivated by a need to keep maintenance costs under control for a contractual period of a decade or more may be able to deliver more reliable service using less equipment than is assumed in the "one for one replacement" scenario of this DEIR.
Other systems have used the opportunity created by a change in rolling stock and a change in system image to make significant improvements in work practices and to move towards more principled economic trade-offs of capital and operating budgeting.
Peer examples should be identified and studied.
The project should consider packages of proposed rolling stock and regulatory changes which minimize capital costs and ongoing operational costs. It would be a huge mistake write the EIR and subsequent RFPs to guarantee failure by requiring FRA-unique rolling stock and consequently locking out the world rail market and locking in 19th-century operating practices.
A combination of a new and fail-safe signal system, interlocks which physically prevent non-PTC/ATS FRA equipment from entering the Caltrain line and prevent non-FRA Caltrain equipment from exiting it, and safe, lighter-weight, contemporary-design, energy-efficient, service-proven rolling stock may be hundreds of millions of dollars cheaper to own and operate and far safer for riders than the combination of old CTC signals, New Jersey Transit locomotives and Chicago passenger cars.
It is possible to achieve superior levels of system safety by combining technology and appropriate regulation than by regulation alone. The wildly successful and widely imitated German "tram-train" systems were introduced over the opposition of a regulatory agency nearly as irrational and intransigent as our FRA; the key will be to quantitatively and irrefutably demonstrate higher achievable safety levels as part of an overall rail system upgrade to international norms.
A stated goal of the electrification is to "modernize Caltrain"; relief from very expensive and very historical Federal railroad regulations would be by far the cheapest and surest way to achieve this goal.
Circa 65% design for electrification infrastructure for the entire corridor from San Francisco to San Jose should be completed as quickly as possible, even if full corridor-long electrification funding is not immediately identified. This design work must be maintained and updated as any works take place along the Caltrain right of way.
Modest funding should be secured as soon as possible for pre-electrification works which can be undertaken in parallel with other projects along the line.
A primary goal of Caltrain capital projects should be to actively coordinate electrification preparatory work with all other projects, particularly signaling changes and track renewals and track realignments. It should be possible to excavate and install catenary pole foundations along any section of track which is booked out of use for maintenance or for some other right of way project. In this way cumulatively expensive incremental costs -- such as flagging, train and passenger delays -- are minimized and all projects proceed more smoothly.
Caltrain is perceived as having a habit of doing the same work over and over on some sections of track; it would be a positive step if electrification broke the cycle of make-work for flaggers.
Real information about train performance improvements should be used to explore significant operational benefits which are not addressed in the existing document. These data are simply not present in the DEIR.
For example, section 22.214.171.124 on page 3-130 claims that "travel times savings onboard Caltrain would average about three percent on express trains and 12 percent on local trains." That is all. Surely more detail can and should be provided.
But note that a 12% saving on the existing (padded) 96 minute San Francisco to San Jose local train schedule brings the journey to 85 minutes. This is within striking distance, especially when combined with boarding improvements made in conjunction with the introduction of new EMU rolling stock, and perhaps with some regulatory relief, of being able to make a round-trip in three hours with one train consist (and possibly one crew).
A SF-SJ regular-interval schedule on half-hour headways can be operated with 25% less equipment -- six trains and crews instead of eight -- given a seemingly small decrease in train running time due to improved performance of electrified equipment.
Such very significant ongoing operational savings should be accounted for, and the costs of rolling stock purchase should be decreased to account for better equipment utilization than in the one-for-one replacement scenarios assumed in the DEIR.
I again note that the benefits of modernized and electrified Caltrain service need to be studied and accounted for as more of a synergistic program than the unnecessarily narrow electrification analysis in the DEIR.
At all costs, Caltrain should avoid everything and everybody connected with the Amtrak North East Corridor "Improvement" Project "north end" electrification. Not only did this project have by far the most expensive electrification costs of any line anywhere on the planet, and not only was it delivered years late, hundreds of millions of dollars over-budget, and under a cloud of litigation and allegations of malfeasance, but the system appears to be over-engineered in a fashion that can only lead to a suspicion that contractual incentives were made for each ton of steel consumed.
The aesthetics of the resulting installations are also horrific, with hugely massive forests of catenary support structures which are out of place in every circumstance, including every other electrified railway in the world.
There are no real "unique Californian" or "unique American" issues which need to be addressed; instead a standardized overhead design standard from a major rail infrastructure provider should be adopted with as little modification as legally possible, and costs, performance and aesthetics should be measured against global best practice, not American exceptionalism.
Portal structures have significant aesthetic (ie NIMBY) impacts, while headspans on mainline track not only require more expensive foundations, but are problematic from a maintenance perspective.
Given Caltrain's generally extremely generous right of way, space exists in most locations to allow side or center pole catenary suspension, and electrification design and track realignment projects should take advantage of this.
Mechanically independent suspension of the OCS on adjacent tracks greatly simplifies electrification maintenance work, allowing other tracks to remain in service, and greatly improves reliability, by confining the effects of many mechanical failures of the overhead system to a single track. In contrast, failure of some components on a headspan structure could close down four mainline tracks at once.
Consideration should be given to allowing the use of double-channel masts, steel tube masts, or concrete masts, not just the steel H-beams assumed in the DEIR. There may be both aesthetic and cost reasons to allow contractors to suggest more appropriate materials.
The DEIS is silent on the San Francisco Municipal Railway's plans to spend millions of public dollars to reroute the close-headway 30 and 45 trolley bus routes to cross the Caltrain line at grade, to the benefit of the Catellus corporation.
Such a crossing of a high-voltage mainline railway overhead and low-voltage trolley bus wiring is almost unprecedented.
The standard industry reference text, "Contact Lines for Electric Railways" by Kießling, Puschmann, and Schmeider has only this to say, in over 800 pages of very detailed design information: "The only known level crossing between an electrified mainline railway and a trolley bus line is at Innsbruck [reference to a German technical paper published in 1989]."
The railway line referenced is a "rarely-used freight-only" line providing access to one industry, quite in contrast to the frequent passenger rail traffic projected along the Caltrain line into downtown San Francisco.
With headways of less than five minutes on both the trolley bus lines, and with similar bidirectional Caltrain headways at peak hours, it will be extraordinarily challenging to design a reliable system to permit this at-grade crossing.
Muni and Caltrain have demonstrated repeatedly that technical innovation is not an organizational forte of either organization; I suggest that, here as elsewhere in matters of railway practice, Caltrain simply adopt tested solutions from elsewhere in the world.
In this case, this means grade separation. Caltrain, working with the City and County of San Francisco, the Metropolitan Transportation Commission, Catellus, the San Francisco Municipal Railway, and most particularly with the Transbay Joint Powers Authority, should actively explore financing and engineering mechanisms such that either grade separation of the Caltrain line and these streets can be achieved, or that electrified Muni lines are no longer required to cross Caltrain at grade.
S-6 section S.2.2.3: Attention should be paid to ensuring that substations are not oversized and overpriced for Caltrain's needs -- and not over-intrusive in their environment. Ideally, physical expansion capacity should be reserved for added power requirements of future high speed rail, or future 10 train/hour service, etc. Where feasible, electrical facilities should also be designed to minimize NIMBYism and not just specified according to the wildest dreams of power engineers.
The horrid design mistakes of the Amtrak NECIP must not be repeated, in which massive steel plates were affixed to urban overpasses, blocking all views from the bridges in the service of some very dubious idea of "safety" -- or perhaps just unthinking expediency.
S-7 section S.2.2.5: Non-FRA rolling stock alternatives must be considered. By requiring that Caltrain rolling stock be built to one-off designs, at immense added cost and with dubious reliability, the proposed menu of rolling stock options guarantees failure for the Caltrain electrification program. One need look no further than the Amtrak Acela fiasco to see where FRA exceptionalism leads.
S-8 section S.2.2.6: A scenario of phased introduction should be considered, in which mixed diesel and electric operations coexist for some time. In particular, phasing of electrification first to Palo Alto with later extension to San Jose would require mixed fleet operation, but other scenarios are possible.
Another example would have diesel locomotives hauling express trains, which require less acceleration performance, while the system's first delivered EMUs are assigned for local stopping trains. Such a scenario has a couple of possible advantages: it allows for early introduction of new electrified service before total fleet replacement is complete, it allows for stretching out of vehicle procurement costs, and it allows greater reuse of existing equipment.
As it is unlikely that another commuter rail startup will be able absorb Caltrain's entire historical replica rail fleet at once, it seems more likely than not that Caltrain will continue to possess a (gradually-shrinking) inventory of diesel locomotives and unpowered Bombardier rail cars even after inception of electrified service. Fiscal prudence dictates that these be used unless there are compelling operating or maintenance reasons not to do so.
Consideration should also be paid to the use of axle detectors rather than older track circuits to drive crossing prediction timers. Note that axle counters are now standard for all train detection in many new installations.
Electrification to Gilroy does not make any operational or economic sense under any projected scenario and must be rejected before its costs drag the entire rest of the system down.
The Caltrain service description should be updated to describe the 86 trains/weekday schedule which will be current "today" at the time the FEIS appears.
The "Year 2001 (80 trains/weekday)" row should be updated to the present day (assuming FEIR publication is post 5 June 2004): ie "Year 2004 (86 trains/weekday)"
Today's Caltrain passenger fleet consists of 93 gallery cars (73 built circa 1986, 20 inexplicably ordered in early 1998), 17 Bombardier bi-level cars, and 14 disintegrating ex-VRE Budd trailers. It is unclear where the count of 19 "Other Existing Cars" comes from.
The assumption that 93 gallery cars will be available in "Year 2020" is unrealistic: 73 of those cars will be more than 30 years old, and will have required replacement by that time.
2-8 section 126.96.36.199: Portal and headspan structures should be avoided wherever possible, and, most importantly, near-future Caltrain track realignment projects should be designed -- as the Bayshore and Lawrence quadruplications inexcusably were not. (The exceptions are tracks in yards and terminals.)
See general comments on headspan and portal structures above.
2-14 figure 2.3-5: The identified location for PS-1 may be needed for a combination of DTX construction and 16th/Common Street grade separation, despite the fact that neither Caltrain nor TJPA engineers seem to have understood this yet.
Further investigation should be undertaken to ensure that there is no potential conflict with these projects. A modest relocation within the identified parcels may be all that is required.
It would be interesting to examine whether the 115' by 120' site size requirement is necessary (due to physics and/or regulation), or whether there is some degree of NECIP over-engineering involved. I do not know the answer. Peer review of 25kv traction substations could be used to help understand the requirements and perhaps to help fit the substations and other facilities within the surrounding urban and urban-industrial environments.
2-19 figure 2.3-10: PS-4 appears to be sited directly within the parking lot of the existing Caltrain station. Is it supposed that relocation of the station to the vicinity of 25th Avenue will have occurred by the time electrification is installed or soon afterwards? This seems a problematic location otherwise.
2-21 figure 2.3-12: PS-5 should be situated between Caltrain tracks and expressway on east side of the tracks if possible; that location is less intrusive, there is no other use possible; and there is less pedestrian access. Or perhaps space could be found underneath the off-ramps connecting the Central Expressway with the San Antonio Road overpass. Despite the "Commercial/Office/Industrial Land Use designation" of the identified parcel for PS-5, it seems that higher uses should be possible for it than a Caltrain autotransformer station.
2-23 figure 2.3-14: ATF-2 should be sited into the Newhall Yard, slated for purchase by VTA (and the future site of the Caltrain CEMOF once the Newhall site nonsense and BART extension insanity run their courses.). In fact, VTA's SVRTC "project" (nudge, nudge, wink, wink) identifies the south-east section of this yard as the site for a BART feeding station.
Caltrain should explore the availability of real estate within the Newhall Yard with VTA.
If available, this should be the preferred alternative for the southern substation for the Caltrain system.
2-24 figure 2.3-15: Locating an open-air substation on an over-sized and prime lot right beside a major railway station is a crazy urban design decision -- admittedly not as crazy as VTA's plans for surrounding the station with parking structures, of course.
I suggest this ATF-2B location alternative be dropped from consideration.
2-30 section 188.8.131.52: It would be useful to provide information on what level of train service (speed, headways) the specified 2 x 60MW power system is designed to accomadate as built, and what future levels of traffic might be powered by upgraded substations occupying the same footprint.
At first glance, it certainly seems that the industrial-sized substations depicted are out of scale with what the traveler would encounter alongside and powering railway lines in Europe or Asia, and it is widely believed that the NECIP installations (pictured) were over-constructed. Do technical peers specify similar installations?
Add an additional option: "Non-FRA Electric Multiple Units", and note that while the vehicle would not have to be "specially procured and designed", and while it would cost around half of what USA-specific equipment would, extensive negotiation with and lobbying of the FRA would be involved, almost certainly accompanied by installation of a more advanced (and expensive) signaling system.
2-43 section 184.108.40.206: See comments on page S-8 re mixed diesel/electric fleet and mixed operation.
2-43 section 220.127.116.11 See comments on page S-8 re constant time crossing predictors.
Note also that a cab signal system incorporating automatic train stop may be a desirable next step to undertake, especially in order to obtain relief from FRA structural "safety" regulations.
OCS infrastructure should be designed to facilitate, or at the very least not actively impede, such capacity amplification at all locations along the corridor where it is feasible to do so.
There are many problems with this section. Firstly, one-for-one replacement of diesel-powered equipment is assumed, ignoring potential improvements in equipment availability through faster turns. See my general comments above about the need for feedback into the cost model from operational simulation, and also my comments on the August 2000 (my, how time flies, and to such little effect) "Draft Assessment of Electrically Powered Rolling Stock Equipment".
It also ignores the possibility that a better-maintained (possibly under a design-build-maintain contract) fleet of low age will have better availability than Caltrain's existing fleet. Certainly Caltrain's present-day 28% passenger car and locomotive spares ratios are numbers which would raise eyebrows at a well-run railway outside the USA.
Secondly, it is still completely unclear what the "Other Existing Cars" category represents: as noted above of table 2.3-1, Caltrain owns 17 non-gallery Bombardier passenger cars as well as 14 old demotored Budd cars, but 19 of nothing. This level of imprecision throws the fleet requirement and rolling stock acquisition cost calculations into some doubt.
Even worse than one-for-one replacement, the EMU option appears to replace 115 loco-hauled cars with 120 EMUs. The logic of doing so is very, very hard to understand. Comparison with other suburban operators suggests that an fleet of 75% to 80% of that size (eg 32x3 car, 24x4) should be more than adequate to provide that proposed level of service.
I also believe that the implied EMU unit prices are excessive, as I noted in comments on the August 2000 report on rolling stock.
The estimated fleet size for the proposed levels of service should also be subject to review. From Table 2.3-8 on page 2-50 one deduces that the proposed 2008 level of service (98 trains/weekday) is more or less just the a circa-2001 Caltrain timetable of 80 trains/day supplemented by 18 express ("bullet") trips, ie five more express round-trips per day than will be offered in June 2004. At most this should require 3 more trains than current operations, for a total of 19 or 20 trains peak demand: support of this amount of extra service should be well within the reserves of Caltrain's elephantine equipment spares ratio. It is unclear where the requirement for a total of 24 electric locomotives and 115 passenger trailers -- let alone 120 EMUs -- comes from.
Repeating earlier remarks, the assumption that 93 gallery cars will still be in service in 2020 is unrealistic; by that time Option 1 (replace locomotives) and Option 3 (replace locomotives and passenger cars) will be identical. This shows the estimated capital costs of tables 2.3-3 and 2.3-6 to be nearly completely meaningless and embarrassingly shoddily developed.
A proper accounting should consider the bulk of the gallery car fleet to be approximately 2/3 depreciated in 2008 and end of life long before 2020; and new rolling stock purchased for start of electrified service should likewise be depreciated over, say, a 25 year lifespan in order to create any sort of meaningful comparative table of capital costs for the different rolling stock options.
This entire section, and the conclusions reached as a result of it, need to be completely reinvestigated and completely rewritten. It is economic nonsense.
2-48 table 2.3-6: Garbage in, garbage out: See my comments on the contents of the tables from which this table is derived.
2-49 section 18.104.22.168: Absent any consideration of the operational advantages of the improved performance of electrically powered equipment, the tables of projected operating costs are of little use ... other than as arguments against undertaking the electrification program.
If faster turn times allow lower crewing costs, the slight extra operating cost of an electrified system show might instead turn into a small savings.
If non-FRA equipment and practices are procured and implemented, One-Person Operation of trains will result in millions of dollars of annual costs.
One-for-one replacement of diesel equipment results, unsurprisingly, in little more than one-for-one replication of existing cost structures, with the added burned of OCS maintenance.
Caltrain: where our motto is "If it's worth doing once, it's worth doing three times."
3-75 section 22.214.171.124: See comments above on TPS placement, referencing pages 2-16 through 2-24.
3-93 section 126.96.36.199: Non-FRA rolling stock, with significantly lower axle loadings, is likely to induce much lower levels of noise and vibration. In addition, noise mitigation is an active issue in rail vehicle design outside the USA (note in contrast that the FRA mandates minimum train noise levels in the Caltrain corridor.)