Caltrain 2004 Electrification EA/DEIR Comments -- Richard Mlynarik

To: Caltrain Electrification staff and consultants
1250 San Carlos Avenue
San Carlos, CA 94070-1306
From: Richard Mlynarik
Re: Comments on April 2004 "Environmental Assessment / DEIR for the Caltrain Electrification Program"

Thank you for the opportunity to provide comments upon the draft EA/EIR for the much-delayed Caltrain electrification program.

Overall comments on the document

  1. Consider system upgrade effects of an overall electrification "package".

    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.

  2. Account for overall life-cycle costs and benefits of new rolling stock.

    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.

  3. No electrification to Gilroy.

    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!

  4. Study a Minimum Operable Segment phase from San Francisco to Palo Alto.

    Several issues are involved:

    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.

  5. DB, DBO, BOOT, etc.

    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.

  6. Rolling stock options should include non-FRA alternatives.

    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.

  7. Complete corridor electrification engineering planning early.

    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.

  8. The EIR needs to contain operational simulation information.

    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 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.

  9. Avoid NECIP; avoid Not Invented Here.

    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.

  10. Avoid portal and flexible headspan structures except in yards and terminals.

    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.

  11. 16th Street and Common Street grade crossings in San Francisco.

    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.

Specific comments on individual pages of the document

Richard Mlynarik
Last modified: Mon May 24 16:56:37 PDT 2004