Regional Plan Association testimony submitted to the Federal Railroad Administration in response to the Northeast Corridor (NEC) Future Tier 1 Draft Environmental Impact Statement.

Evaluation of DEIS Findings and Alternatives

RPA strongly supports the investments proposed in Alternatives 1 and 2, which would bring the NEC to a state of good repair and address major bottlenecks. The first priority must be to create a solid foundation to build upon by restoring all part of the NEC to a state of good repair.

To tap into the full market potential of the Northeast corridor, RPA recommends that the FRA pursue Alternative 3, with the following conditions:

1. The initial focus should be on high-speed rail (HSR) for the southern alignment, with two dedicated tracks (all or part of the distance) between New York City and Washington, D.C.
2. The two new dedicated HSR tracks between New York City and Boston for the northern alignments require further analysis before either should move forward. This analysis should also include the consideration of a third alignment – two new tracks along the existing New Haven Line – which might be superior to the Long Island or inland alignments.
3. A more thorough analysis of market demand in the corridor is needed, which should include an assessment of the potentially transformative impacts of higher- and high-speed rail services.

The Northern Alignments

With regard to the northern alignments, the findings of the NEC FUTURE DEIS don’t examine the alignment options in sufficient detail and with defensible assumptions to support or reject any northern alignments at this time. RPA questions many of the assumptions made in this analysis and its completeness, and doesn’t wish to foreclose the possibility of either of the two new dedicated HSR northern alignments and/or additional improvements to the New Haven Line to support HSR and the exploration of yet unidentified options. We respectfully request that the FRA further investigate the New York City-to-Boston alternatives to understand the benefits, costs and implications of three alignment alternatives, including the New Haven Line. Particular attention should be given to the potential market for high-speed service given current and potential development patterns and current and potential transit connection options along each of the three northern alignments.

HSR Ridership Demand and Economic Benefits

The current analysis doesn’t account for a host of ridership opportunities that could be created with high-speed intercity connections with local transit systems, airport /rail connections, and travel generated by greater economic activity in detail for each northern alignment. The economic benefits of intercity service are assessed for each northern alignment in the DEIS , but construction/O&M job growth, travel time benefit for regional services, greater connectivity to air-to-rail, and general increases in economic activity aren’t explored in detail. We strongly recommended pursuing a detailed analysis of these costs and benefits for each of the northern alignments.

Further study of the northern alignments is needed to understand the following:

1. The extent to which the right-of-way can be grade-separated, either above or below ground, to speed service, albeit at higher costs and the accompanying effects or benefits of this separation.
2. The extent to which the right-of-way can avoid existing development, particularly residential neighborhoods.
3. The extent to which development can be built to not interfere and even improve existing commuter regional services.

Phasing and Implementation

The NEC FUTURE DEIS doesn’t provide a set phase or implementation timeline for improvements, stating they will be explored in the final environmental impact statement. Given the additional costs associated with extending timelines for major capital construction, RPA recommends that the implementation timeline should not be drawn out and that the number of phases should be limited.

Principles to Guide Future NEC Investment (response to Purpose and Need)

RPA suggests the following principles to guide the FRA in evaluating the benefits of the high-speed rail action alternative (Alternative 3) and possible alignments. As articulated in the NEC FUTURE DEIS, the Northeast intercity rail system is in need of hundreds of millions of dollars of additional investments annually just to maintain current service levels and without addressing the state of good repair backlog. Any long-term investment plan for the NEC should begin with bringing the railroad up to a state of good repair. Additional investments to enhance the capacity for intercity service should favor those locations, typically metropolitan areas, with a robust transit ridership to complement and interact with intercity service. Near-term and mid-term investments for alignments and stations should support economic growth in existing large and medium-sized cities in the NEC. Longer-term investments should not only continue to support these locations but also should be used to transform areas that encourage and support compact urban development.

Commuter Service

Intercity rail improvements must accommodate the operational and market needs of commuter services. While intercity rail services are important, helping to decongest interstate highways and airports, the volume of travel within urban areas far exceeds that of all intercity travel. Amtrak today carries 11.6 million people per year between Boston and Washington, the full length of the NEC.[1] By comparison, NJ Transit - one of three railroads in the New York metropolitan area - alone carries an estimated 85.6 million riders annually.[2] Seven other transit operators also use the NEC to provide commuter rail services between Washington and Boston. Acknowledging the demand on commuter rail services and accommodating these operators is necessary for an accurate modeling of the capacity and determination of investments needed for seamless mixed operation of intercity and regional services.

Air-Rail Diversion

Higher- and high-speed rail services should be designed to capitalize on proximity of the NEC to adjacent airports to establish multi-modal connectivity. Currently, this is possible in Baltimore, Philadelphia, Newark and Providence, but not for other major airports in the region, most notably John F. Kennedy Airport. But even with new air-rail connections, our analysis indicates that high- and higher-speed rail wouldn’t have a significant effect on airport congestion overall. It is only in the Boston-New York/LaGuardia market where those connections could have a substantial impact, and that air market represents a small share of airport congestion in New York and in the Northeast.[3]

Cost

Project costs must be controlled, and the NEC FUTURE DEIS doesn’t explore potential cost-saving measures by minimizing phasing or through the use of various financing and project delivery alternatives. Additionally, by being operator neutral, the NEC FUTURE DEIS is limited in a detailed assessment of operation costs. RPA recommends the NEC FUTURE DEIS more fully assess capital and operation cost reductions measures, expanding the scope of the DEIS to explore innovative financing and procurement strategies.

Economic Effects and Growth, and Indirect Effects

The transformative economic benefits of faster rail travel are understated in the Tier 1 DEIS. RPA recommends the FRA more closely investigate the travel time savings and cost savings resulting for the regional commuter services that share the corridor with Amtrak rather than the simplified User Benefit metric. Reduced wait time for regional services is an insufficient metric to base the analysis. The reliability of infrastructure on the corridor and higher speed of the service will boost on-time performance and reduce overall travel times, not only passenger wait time. Commuter rail services also will benefit from improvements made to the corridor, services that provide travel for more daily passengers than intercity alone. Additionally, as shown under Economic Growth in Chapter 3 each major market has its own associated economic costs and benefits, applying a single (and low) metric for travel time savings per hour of $13.20, for all geographies, is potentially understating the benefits of each alternative. Assessing the travel time savings resulting from improvements to NEC that create greater reliability of regional services in detail for each alternative will help to better distinguish the alternatives in the final cost benefit analysis. Furthermore, separating the benefits of each northern alignment for Alternative 3, as was done for the intercity analysis, should be done for regional rail.

In addition to understating the benefits for regional markets by reducing travel times, the NEC FUTURE DEIS is limited in assessing the future population and job access to the major employment markets of each alternative. The assessment of population and employment growth described the Potential Indirect Effects in the Three Metropolitan Areas and Representative Station Areas in Chapter 6 is very cursory for each alternative, and especially Alternative 3, as it doesn’t include any detailed assessment of the northern alignment alternatives. Additionally, the analysis lacks detail for future job and resident access to key markets served along the corridor, especially the central business districts of Boston, New York, Newark, Philadelphia, and Washington, D.C., since representative station areas only include Baltimore, Hartford and Ronkonkoma. Reporting future resident and job access by station should be done using the base projections reported in Chapter 6. Incorporating future population and employment growth into ridership estimates will improve the assessment of alternatives for the final cost-per-rider comparison.

Lastly, there is some mixing of timelines for the economic benefits and project costs. Construction and O&M jobs benefits are calculated for a 20-year construction period, while capital construction costs have been estimated for a 25-year timeframe. Additionally, the monetized value for travel time savings are annualized but not cumulative in a similar timeframe as the construction timeline, yet presumably the lifespan of the time savings benefits would extend far beyond 2040. Additionally, these travel time savings are calculated for ridership estimates that don’t incorporate future population and job growth along the corridor. RPA recommends that the monetized benefits of job growth and travel time savings are assessed alongside project costs for a consistent timeframe for all alternatives and alternative alignments.

Summary of Recommendations

While RPA supports the NEC FUTURE study, the FRA should further refine and expand the study’s methodology and technical analysis. Specifically:

1. The FRA should pursue Alternative 3, with the following conditions:
   
   1. Initial focus should be on HSR for the southern alignment, two dedicated tracks (all or part of the distance) between New York City and Washington, D.C.
   2. Further investigation is required for northern portion between New York City and Boston. This analysis should include an assessment of the full costs and benefits of each alignment, as well as the consideration of a third alignment of two new tracks along the existing New Haven Line.
   3. Further investigation is required of potential demand for HSR in all markets.
2. In the FEIS, the implementation timeline shouldn’t be drawn out, and the number of phases should be limited.
3. The FEIS should assess capital and operation cost reductions measures, expanding the scope of the DEIS to explore innovative financing and procurement strategies.
4. There should be a detailed investigation of the travel time savings and cost savings resulting for the regional commuter services that share the corridor with Amtrak rather than the simplified User Benefit metric.
5. Monetized benefits of job growth and travel time savings should be assessed alongside project costs for a consistent timeframe for all alternatives and alternative alignments.