RPA On LD Study: Go Faster, Get Everyone At The Table

By Jim Mathews / President & CEO

Today is the day when formal comments are due on the output of the third round of the Federal Railroad Administration’s long-distance rail study, and your Association’s comments focused less on individual routes and more on the need for genuinely independent oversight and a much more ambitious schedule.

We told the study leaders that “we...fully agree with the motivation behind the study team’s proposed ‘Long-Distance Public Committee’ to be created by Congress. However, we also believe that such a body would need to be more than just advisory in nature. Just as the State-Amtrak Intercity Passenger Rail Committee has some limited statutory role in setting the terms for state-supported Amtrak services, the long-distance committee should also have some way of exerting influence beyond simply surfacing preferred ideas.

Rail Passengers formally recommended the creation of “a National Long-Distance Rail Service Commission – likely as part of the Dept. of Transportation – to bring together all the Federal agencies with a role to play in building out this new Network, as well as key stakeholders such as tribes, organizations representing state agencies, local elected and appointed officials, relevant Class I representatives, and passenger groups.”

Although the details vary around the edges, many other advocacy groups and entities offered similar recommendations.

As I’ve written in previous blog posts, we applaud this study’s scope, ambition, detail, and commitment. Truly! Our biggest beef was with the inordinately long implementation schedule assumed in the study. From my perusal of other commenters’ filings, it’s clear that there was nearly universal agreement that getting new routes up and running needs to happen more quickly than the 2040 to 2060 period envisioned in the third-round draft materials.

“Rail Passengers believes the FRA should use the study’s publication and conclusions to advance a more robust timeline for route development, design, and implementation,” our comments letter said. “The conceptual timelines offered on Slide 154 of the Round Three results slide deck are far too long to be politically and fiscally feasible. The ‘Near Term’ implementation timeline posits a requirement for sustained political and funding support across six presidential administrations, and ‘Long Term’ would take potentially ten Presidents or more to carry out.”

We think there are lot of reasons to believe these routes could be put in place more quickly than outlined. For one, the study assumes no new greenfield construction – these trains will run for the most part in places where trains already run today. This should make it easier to rely on what are called “categorical exclusions” to avoid having to spend millions of dollars and several years – the FRA’s average is over five years – producing a redundant full-bore environmental impact statement. Construction should be limited to things like passing sidings, platforms, stations, and the like, and take place in places where train-related infrastructure already exists and the environmental impacts, if any, are already well characterized.

Your Association proposed using the nearly two years’ work done on this study as head-start inputs into any Service Development Plan for new routes, and would slim down the overall schedule to two years for service development, followed by three years for design, and then five years for construction.

To run trains on existing track at relatively low volumes should not require 20 years of investment and development. The fact that it does today does not make it inevitable. Instead, it means we’re doing it wrong.

You can read our formal comments letter by clicking here. Meanwhile, we’re preparing our materials for the fourth and final round in late May or early June, which will focus on capital investment needs, characterizing economic and social benefits, and – we hope – refining the timeline for implementation. Stay tuned!