Regional Plan Association submnitted the following comments to the Federal Railroad Administration on the NEC Future Tier 1 FIES, to improve rail service along the Northeast Corridor between Washington, D.C., and Boston.

RPA strongly supports increased investment in intercity, regional and commuter passenger rail. Public transportation expands mobility and access to jobs and reduces greenhouse gas emissions. RPA has long advocated for faster and more reliable passenger rail service for the tri-state region. In particular, we have strongly championed improvements to the NEC, both between New York and Washington, D.C., and north of New York along the New Haven Line for both Amtrak’s inter-city rail and Metro-North Railroad’s commuter service. The existing infrastructure along the Northeast Corridor, much of which is well beyond its replacement age, is in serious need of repair and upgrade to meet the needs of today’s commuters and regional rail passengers.

As identified in our 2014 report, Getting Back on Track, which called attention to the need for capital investment in the New Haven Line, we noted that at the current pace it will take more than 20 years to achieve a state of good repair. In other words, passengers will continue to suffer through longer trip times and delays caused by continuous track outages required to accommodate the reconstruction of critical components of the New Haven Line for another two decades. The nation’s busiest rail line in the nation’s most productive region cannot wait that long to simply achieve a basic state of good repair. And that state of good repair would only fix what it is broken. It would not improve service or reduce travel time along the line.

The Preferred Alternative outlined in the NEC Future Tier 1 FEIS includes the general goals of:

• More frequent trains
• Improving connections between trains
• More reliable service
• Improving trip times
  • 35 minute reduction between Washington and New York
  • 45 minute reduction between New York and Boston
• State of good repair improvements
• Adding new tracks to bring the NEC to four tracks at most locations
• Eliminating major choke points that cause delays

Regional Plan Association supports these general goals and applauds FRA for advancing a program to improve service and reduce travel time on the Northeast Corridor. As described in the Tier 1 FEIS, these goals ​“establish a framework for future projects that may be undertaken and financed by the federal government, states and railroads in the coming decades. The Preferred Alternative indicates FRA’s direction toward selecting an investment plan for the NEC.”

This framework, outlined on the map below, illustrates general locations of new tracks, new segments and chokepoint relief projects. This Preferred Alternative is, in essence, a master plan for the Northeast Corridor with projects outlined but not clearly defined. According to the Tier 1 EIS, the specifics of these projects will be further developed during Tier 2 project development process.

Some future projects that will impact the region specifically highlighted in the Preferred Alternative include:

• High-speed rail between New York City and Washington DC
• New segment between Old Saybrook, Conn., and Kenyon, R.I.;
• Upgraded Hartford/Springfield Line, connecting New York to Boston; and
• New hub station at Greens Farms.

Source: Federal Rail Administration

While RPA commends FRA for advancing the complex project of improving rail service along the Northeast Corridor, we would like to highlight some issues that should be considered prior to finalization of a selected alternative and the issuance of a record of decision.

1. High-Speed Rail Between New York and Washington DC

The preferred alternative does not provide for a separate two track dedicated high-speed right-of-way the entire length of the corridor between New York and Washington, reducing the attractiveness and capacity of future intercity service between the cities. While we applaud the FRA for adding tracks, including several new major segments, the preferred alternative fails to completely address the bottlenecks that severely limit speeds on the NEC as it passes through major metropolitan areas, such as Philadelphia. This decision (likely made to lower costs) has reduced the travel times savings from 65 minutes in Alternative 3 to 35 minutes in the final Preferred Alternative, which is even less than the 45 minute travel time savings predicted between New York and Boston in the FEIS. The FRA should adopt the Alternative 3 alignment south of New York City to induce (and divert) more intercity travelers to rail and ensure that there is sufficient capacity to accommodate future demand between our two strongest intercity markets.

2. Shore Line East

The Preferred Alternative includes a new 50-mile inland route between Old Saybrook, Conn., and Kenyon, R.I., as well as a station in New London. We recognize the benefit of two new inland tracks to provide redundancy on the portion of the Northeast Corridor that is most vulnerable to flooding and support enhanced rail service overall. But we believe that significant improvements in travel times and reliability between New York and Boston will best be achieved under the proposed alignment through Hartford to Providence via the University of Connecticut (Alternative 2 and 3). This alignment would be the most efficient and direct means of providing faster service. At the same time, we feel that existing Shore Line East alignment should continue to provide a connection to Providence and Boston and should be upgraded to improve resiliency and reduce vulnerability to flooding.

3. Barnum Station Hub, Bridgeport

The Preferred Alternative makes no reference to Barnum Station, a new station proposed north of Bridgeport Station. This new station is advancing through the environmental review process and significant state and federal resources have already been committed to advance the design and implementation of this new station. FRA should consider leveraging this existing investment in creating a new hub station at Barnum Station rather than the proposed hub at Greens Farm. As currently proposed, two additional tracks would extend to Greens Farms, which would serve as a transfer point to super express service. We feel strongly that the two additional tracks should be extended to Bridgeport to allow the new Barnum Station to serve as a hub, rather than creating a hub at Greens Farms. To do this would require a new tunnel or structure through downtown Bridgeport that would also address the speed bottleneck ​“s” curve at the Bridgeport station. The new alignment would allow trains to bypass this slow-zone and directly serve the new Barnum station.

There is an opportunity to add economic value to this planned investment by creating a Hub at Barnum Station, which would support a significant transit oriented development plan that is being advanced by the City of Bridgeport. According to a recently released report by Goody Clancy & VHB, ​“The Barnum Station District has the potential to become a Regional Center. This major economic development opportunity has few parallels along the Northeast Corridor, and is a prime opportunity to expand economic growth in southwestern Connecticut.” The Barnum Station District has the potential to attract and create 4,000 or more new jobs and 1,000 new housing units within walking distance of the station over the next 25 years (see Exhibit B). Greens Farms isn’t a significant population center and doesn’t offer an economic development opportunity of nearly this magnitude.

Source: Barnum Station TOD Plan, Goody Clancy & VHB, 2017

4. Sea Level Rise

All proposed track and related investments along the NEC should address sea level rise. RPA’s December 2016 report, Under Water, details the location of 1’, 3’ and 6’ sea level rise in the region over the next 30-100 years. In coastal Connecticut, affected areas include Bridgeport, New Haven, Stamford, Fairfield, Milford, Branford, East Haven, Greenwich, Norwalk, Stratford and Westport. In New Jersey, sea level rise will affect NEC tracks in the Meadowlands area between New York Penn Station and Newark Penn Station and will also impact the Secaucus station. (see Exhibit C).

Source: NOAA and the Regional Plan Association

5. Regional Coordination
According to the Tier 1 EIS, ​“Achieving the system-wide benefits of the Preferred Alternative will require implementation of many interrelated projects, requiring a coordinated process over time. The Preferred Alternative provides a flexible approach to implementation, allowing investments to be made in phases as funding becomes available. States and railroad operators would work together to determine the order in which the improvements are made and affected communities would have the opportunity to help shape rail infrastructure projects during Tier 2 project development processes.” FRA hasn’t proposed a regional governance structure that would facilitate coordination of these interrelated projects over time. RPA is concerned that without a clear understanding of the mechanism for this coordination and/or an entity tasked with this role, there is a significant risk for lack of coordination and prioritization of investment among the many Tier 2 projects that will be developed subsequent to the record of decision.

6. Consideration of Community Impacts: RPA supports enhanced rail service, but also recognizes that the Northeast Corridor runs through very densely populated parts of the country. We hope the FRA and implementing agencies involve communities early in the Tier 2 project development process.