1 In the version of the spreadsheet model that we received, column headings are missing and formulas have evidently

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1 ROCOG STAFF COMMENTS ON THE DRAFT COMPREHENSIVE MINNESOTA STATEWIDE FREIGHT AND PASSENGER RAIL PLAN I. Vision We support the Plan s conclusion (page 4-36) that high speed passenger rail should focus in the long range on separate tracks capable of handling speeds of 150 mph and higher. Acknowledging the long term necessity of dedicated tracks capable of 150 miles per hour or higher is a step in the right direction. However, we continue to see a need for the Plan to express a broader long range vision of high speed rail. At a time when other major global economic centers (such as China, Japan, and Western Europe) are building passenger rail systems capable of speeds over 200 miles per hour, the Minnesota Plan should not settle for a vision tied to existing freight lines or to speeds up to 110 miles per hour. The Plan should instead reflect goals consistent with the national high speed passenger rail vision of transforming the nation s transportation system. Passenger rail networks that are not competitive in terms of travel time will not attract riders away from automobiles or air travel. High speed rail will be cost effective if and only if it is demonstrably superior to, and attracts riders from, competing modes. Minnesota needs true high speed rail connecting Chicago and the Twin Cities. II. Chicago to Twin Cities Corridor We support the Plan s inclusion of the Chicago-through-Rochester corridor as a first - phase option for further study in detailed corridor studies. Although the comparisons of corridor alternatives are perhaps generally useful as a screening tool, detailed corridor studies will be needed to develop more reliable forecasts of ridership, revenue, capital and operating costs, and return on investment. III. Demand Factors Assessment We remain concerned about the data and methodology used to estimate current demand and forecast future demand for inter-city travel in general and high speed rail travel in particular (Table 3.1 of the Draft Plan on page 3-27 presents the consultant s estimates of total travel demand between the Twin Cities and selected cities for 2005). At our request, we were provided a copy of the spreadsheet model used to generate travel demand estimates and forecasts. The spreadsheet model is not documented sufficiently 1 to enable our staff to thoroughly understand its methodology, but it is clear that the model relies heavily on average daily highway traffic data between major cities to derive city-to-city travel estimates and forecasts. Since traffic levels between pairs of cities depend in part on sources of traffic unrelated to the cities of interest (including both traffic originating from or destined to areas beyond the cities of interest and traffic originating from or destined to areas between the cities of interest), the data does not reflect inter-city travel consistently. In the case of St. Cloud and the Twin Cities, for example, the volume used to represent auto travel is influenced both by traffic oriented to areas north and northwest of St. Cloud and by heavy traffic originating from or destined to intervening communities in Sherburne and Wright Counties. The same distortion occurs in the analysis of Mankato, where much of the traffic between Mankato and the Twin 1 In the version of the spreadsheet model that we received, column headings are missing and formulas have evidently been replaced with values, contributing to a lack of transparency and making the task of deciphering the relationships among variables quite difficult. 1

2 Cities originates from or is destined to the area north of Mankato, between Mankato and Minneapolis. The result distorts the comparison of inter-city travel between city pairs. As pointed out in ROCOG staff comments on Technical Memorandum 3, pages 8 through 11, the differences in estimated total travel are not accounted for by differences in population, commuting travel, total employment, lodging employment, or other logically relevant variables. The travel demand figures appear relevant to commuter-rail service, where frequent stops along the corridor (mimicking a freeway s spacing of interchanges) serve the intervening population, but do not represent the apples-to-apples comparison of inter-city travel that MNDOT needs. In the case of St. Cloud, because the Northstar line is a commuter line and not chiefly an inter-city system, it is appropriate to reflect intermediate destinations in travel demand forecasts. It is not appropriate to compare those commuter forecasts to true inter-city travel forecasts. The analysis fails to accomplish the apples to apples, data-driven comparison MNDOT asked the consultant to prepare. IV. South Suburban Station We are particularly concerned that the analyses of the Chicago to Twin Cities through Rochester and the standalone Rochester to Twin Cities corridors exclude a station serving the growing south suburban Twin Cities area. In the first place, the analysis is at too general a level to draw conclusions about the feasibility of such a stop. Secondly, the south suburban area is part of an area of high employment and population growth (with such facilities as UMore Park) that will benefit from direct connection to the regional high speed rail network. Previous comments from ROCOG noted a failure to account for the potential influence of intermediate stops along corridors, so that growth centers such as Rosemount and Eagan, served by a potential Rochester route, are not factored into demand projections. More detailed corridor studies or a future Plan amendment should include a study of the feasibility of such a station. In contrast to the MSP stop, which is included in the Plan s assessment of the two Rochester routes, the south suburban stop would not require a bridge over the Minnesota River, which with related connections totals $253.8 million in capital costs (page 4-40 and 4-41). ROCOG staff supports a connection to MSP as a reasonable high speed transportation system improvement, despite the fact that it distorts the relative assessment of farebox recovery for alternative corridors. However, we also consider that a south suburban station would generate a system-level benefit and thus warrants further study. V. Undue Emphasis on Expediency We are concerned that the study favors incremental improvements and tilts the analysis against greenfield routes. As we noted in earlier comments on technical memoranda, the costs of greenfield routes are inflated (for example, with an assumed average right of way acquisition cost of $50,000 per acre for greenfield routes in rural areas 2 ) and the concerns about delays are exaggerated. In addition, since the Plan s ultimate goal (as stated on page 4-36) is travel on separate tracks at speeds in excess of 150 miles per hour, greenfield routes are the most practical way to achieve true high speed rail. The Plan should not jeopardize achieving the longterm goal by focusing on short-term ease of implementation. 2 As pointed out in ROCOG comments on Technical Memorandum 6, the cost of $50,000 per acre is inconsistent with the experience of MNDOT s District 6 office, where right of way staff estimate rural land acquisition costs of roughly $6,000 per acre including severance-related costs, and fringe urban land costs of $25,000 per acre. 2

3 VI. Infrastructure Assessment Accounting for the shares of corridor expenses that should be attributed to system-level improvements, to freight rail, and to passenger rail complicates the comparison of corridors. The Plan should clarify these issues by setting forth a basic set of rail infrastructure improvements needed for the entire system, and then should set forth the additional marginal increases in improvements needed for each alternative corridor. We appreciate the fact that many of the infrastructure concerns communicated in our response to Tech Memo 6 have been reflected in the draft Rail Plan (reducing the capital cost by over $400 million). However, issues remain related to demonstrating the cost-effectiveness of individual links, especially when those links are relatively expensive in comparison to the corridor cost. VII. Farebox Recovery The Plan in effect ranks corridor alternatives in terms of estimated farebox recovery. The farebox recovery value is very sensitive both to the travel demand estimates and cost assumptions. Changes in either or both travel demand estimates or cost assumptions could significantly affect the estimated farebox recovery and relative rankings among the Phase I alternatives. More detailed corridor studies or a future plan amendment should provide more realistic cost assumptions as well as more realistic demand forecasts, providing the marginal costs and marginal returns on investment of separate elements of the alternatives. The current corridor rankings of farebox recovery among Phase I alternatives should not be used as a basis for prioritizing Phase I projects. VIII. Detailed Comments Page Paragraph Comment 1-3 Last Table & 1-15 Figures 1.7 & Among the key elements should be a goal to shift an increasing proportion of freight movements to rail, especially intermodal and interstate movements, but also for those freight customers served by short line railroads, where the Rail Plan proposes public investment in safety and upgraded rail. Incremental advances are not always consistent with demonstrating demand or with leaving open all future options for true high speed rail. The Plan should not preclude true high speed initiatives by focusing too narrowly on an incremental vision. For reasons discussed above, resulting from the consultant s heavy reliance on automobile average daily traffic in their spreadsheet model, the table confuses travel associated with frequent stops, best served by commuter rail, with true intercity travel between city pairs. This significantly distorts the comparison among St. Cloud, Duluth and Rochester and probably also overstates Mankato and Eau Claire travel demand. Because the demand side of the farebox recovery values is based on flawed data, these figures provide only the crudest basis for prioritizing categories of projects. The demand side errors relate to the fact that auto ADT reflects origins beyond and between city pairs. Further comments on these figures and their associated data tables are provided below in the comments on pages 5-9 through This paragraph suggests the Tri-State II Study as concluding that a route through Rochester had the best benefit/cost ratio and should be implemented FOLLOWING the incremental upgrading of the existing Amtrak route. This misrepresents the 3

4 Page Paragraph Comment conclusion of the study. Tri-State II simply assumes the MWRRI proposal as the base case based on work of others and does not recommend incremental upgrading of the river route nd bullet in box Figures 3.4 & Section Table Table Table 4.20 This paragraph discusses completing high level NEPA documents and combining this with information from MWRRI to form a service development plan. The results of the Tri-State studies, which provide support / justification for true high speed rail service development, should also be included in the information providing the background for NEPA documents. The figures are switched around and do not correspond to the figure titles and text. The trip table from the Tri-State studies should have been relied on as the basis for modeling demand. The statement that a full scale trip table does not exist is in error. Substituting the as yet essentially undocumented spreadsheet model in its place results in flawed demand figures. While the consultant emphasizes not considering outlying commuter rail markets such as Cambridge and Rosemount in its city-pair analysis, the model s heavy reliance on automotive traffic volumes results in intermediate travel origins contributing heavily to estimated city-pair travel demand. This especially distorts the results for St. Cloud, Mankato, and Eau Claire. For reasons discussed above, resulting from the consultant s heavy reliance on automobile average daily traffic in their spreadsheet model, the table confuses travel associated with frequent stops, best served by commuter rail, with true intercity travel between city pairs. This significantly distorts the comparison among St. Cloud, Duluth and Rochester and also overstates Mankato and Eau Claire travel demand. The estimated Right of Way cost of $50,000 per acre for greenfield routes (which applies significantly only to the Rochester corridor) is inconsistent with the experience of MNDOT s District 6 office in acquiring right of way in rural areas (where greenfield acquisition is proposed to occur) and with estimates provided by other consultants. This is especially the case where right of way acquisition does not confer any commercial development advantage (as would be the case with a rail line without a station). The value is inconsistent with estimated market values in District 6, where right of way staff estimate rural land acquisition costs of roughly $6,000 per acre including severance-related costs; fringe urban land costs of $25,000 per acre (the example given being the Pine Island interchange area); and properties in Rochester at $50,000 per acre. Since the right of way for the proposed Rochester Route is predominantly rural, and since it is proposed to use existing rail lines once the corridor reaches the south suburban fringe, we suggest that the study rely on the Tri-State III estimate of $16,000 per acre. ROW cost estimates appear to be roughly four times as high as estimates from other studies, including a study relying on input from Canadian Pacific Railroad on right of way acquisition costs. Applying generally to all infrastructure cost tables, it appears that engineering and contingency costs should be applied to passenger rail capital costs as well as to freight costs. Where alternatives using existing freight lines that have high numbers of tight-radius curves, achieving modestly higher speeds will also likely require acquisition of right of way. Some estimate of the costs based on the number of such curves is necessary for a true apples-to-apples comparison Table 4.22 Freight related costs for the Rochester to Twin Cities corridor are substantially 4

5 Page Paragraph Comment reduced from the figures provided in Technical Memorandum 6, from a total of $425.9 million to $79.4 million. There are also substantial reductions in rolling stock; these are offset, however, by improvements related to service to MSP Airport, with a total cost of $253.8 million. The data should be presented to support the evident conclusion that ridership revenue would yield a positive benefit cost ratio for this link. We also consider that a south suburban station stop, while adding slightly to travel time, would yield farebox revenue without incurring such costs. It is therefore worthy of further study in detailed corridor studies Table 4.23 Freight related costs for the Chicago to Twin Cities through Rochester corridor are substantially reduced from the figures provided in Technical Memorandum 6, from a total of $715.7 million to $243.2 million. The difference between this total and the Rochester to Twin Cities total represented in Table 4.22 is the cost of the La Crescent swing bridge and associated engineering and contingency costs. Passenger side costs increase from $1,356.5 million to $1,445.9 million due to the reductions in rolling stock costs being offset by $253.8 million in costs related to service to MSP. The total of freight and passenger costs is reduced from $2, & & 5-12 System Accessibility Table 5.4 & 5.5 Figures 5.1 & 5.2 million in Technical Memorandum 6 to $1,689.1 million in the draft Rail Plan. Mixing county level population estimates (for smaller cities) with Metropolitan Area population estimates (for larger cities) for determining system accessibility presents another instance where the use of different data sources skews results. Using Census Tract data within a fixed buffer area would be a better approach. The operating and maintenance costs in these tables, representing base and best cases, do not appear to have been reduced to reflect the reduced number of train sets reflected in Chapter 4 for the Twin Cities to Rochester route. The capital cost figures also do not appear to match the figures in Chapter 4. The farebox recovery for the Rochester alternative for the Chicago to Twin Cities corridor in table 5.4 (120%) does not match the farebox recovery in Figure 5.1 (118%). The demand figures appear inconsistent with the figures provided in Chapter 3 (pages 3-28 and 3-29), where in the base case, for example, the sum of Red Wing and Winona rail travel is 90,000 versus 531,000 for Rochester, yielding a difference of 441,000. That difference is not consistent with the differences among the river route, the Rochester alternative for the Chicago to Twin Cities route, and the Twin Cities to Rochester route. While the capital costs used to locate the centers of the circles representing farebox recovery appear to relate generally to the passenger-related costs derivable from the tables in Chapter 4, they do not appear to match the capital cost figures in the preceding tables in Chapter 5. Because the farebox recovery estimates depend so heavily on a fundamentally flawed approach to estimating intercity travel demand, they should not be relied on in future detailed corridor studies. 5