This letter was sent to the Massachusetts Department of Transportation during the comment period for the draft East-West Rail Study by Steve Strauss, and is published as a guest post with his permission. 

Thank you for the opportunity to comment on MassDOT’s East-West Rail Study.  The document represents an informative first step with good documentation of existing conditions, understandable maps and tables and identification of three reasonable alternatives.

The Study does a good job of breaking the project into the three logical and distinct segments (BOS to WOR; WOR to SPG and SPG to PIT) and explaining the particular situations, options, costs and travel times for each segment.

That said, MassDOT and their primary consultant, WSP, seem to have set up the study, to examine the costs and benefits of expanding east-west passenger rail service, so as to portray the idea in the worst possible light.  Two primary decisions by MassDOT result in seemingly high capital costs and low ridership creating low cost-benefit scenarios for improving passenger rail service.

First, MassDOT established the western terminus of the study in Pittsfield, a city of 44,000 people rather than Albany, NY, a city of 97,000, in a metro area of well over 500,000.  Albany is the 10th busiest Amtrak station in the United States and has passenger rail connections to New York City, Chicago, Montreal, Rutland (VT) and Toronto.  In addition, the Albany-Rensselaer station has existing train storage, maintenance facilities, crew quarters and a commissary that could be made available for expanded service to Boston at a likely lower cost than building new facilities in either Springfield or Pittsfield.

Extending Massachusetts East-West service an additional 38 miles to Albany provides greatly enhanced network connectivity and a much larger terminal ridership market for trip origins and destinations.  It is critical that New York State DOT’s Rail Division be brought into this effort.

Second, MassDOT has presented the full build-out costs of each alternative without acknowledging that most states take a much more incremental approach to improving intrastate and interstate passenger rail service.  If you look at two very successful state-focused expansions of passenger rail – North Carolina’s Piedmont service between Raleigh and Charlotte and Maine’s Downeaster, both have had significant initial capital costs, but both have expanded incrementally, growing service and making additional capital investments in line with growing ridership over an extended time period.

The study demonstrated that the cost projections are in-line with what the Commonwealth is experiencing on other rail corridor improvement projects.  MassDOT should have provided a more positive tone to the study and included Albany as the western terminus to have presented a more realistic picture of how to expand passenger rail service across the Commonwealth.

Governance and Operations

Discussions of how the Commonwealth might initiate and/or operate expanded east-west passenger service omitted or downplayed expansion of a Rail Division within MassDOT.  Rail divisions are a fairly common practice for states with PRIIA Section 209 state-supported Amtrak service.  North Carolina and Michigan oversee extensive state supported passenger service operated by Amtrak.  Connecticut uses a third-party operator overseen by Connecticut DOT for CT Rail.  Massachusetts DOT currently participates in the Section 209 State-supported trains program as well as the cost-sharing arrangements of Section 212 pertaining to the Northeast Corridor.

Accordingly, in the short-term, MassDOT could add a second daily round trip between Albany and Boston operated by Amtrak and funded by the Commonwealth through the Section 209 program.  While Amtrak is a high cost provider, this is the fastest way to respond to the interest of Western Massachusetts in having greater connectivity with the Boston area.  This approach also requires negotiation with CSX Transportation.

Housing Costs and Other Economic Benefits

The report acknowledges that more work needs to be done to identify the economic benefits of enhanced east-west connectivity through frequent passenger rail service.  Similarly, more work needs to be done on how the high cost of housing limits economic growth in the Boston area and how reductions in travel time between Worcester and Boston and perhaps Palmer and Boston could expand the availability of affordable housing by expanding the Boston commuting shed.  This is a real, measurable benefit that should be considered in the next stages of this project.

Suggested Enhancements to This Study or Future Studies/White Papers

  1. Formally bring New York State DOT into the planning process.
  2. Develop more incremental approaches to implementing one of the 3 recommended options.
  3. More clearly state the assumptions on high and low level platforms for each station. (Unfortunately, CSX generally restricts high level platforms in mixed freight and passenger use territory.)
  4. Detail station parking assumptions associated with ridership forecasts. Introduce discussion of fare revenue to meet operating costs. The Commonwealth of Virginia is meeting it’s “above the rail” operating costs from fare revenue for state-supported extensions of NEC Regional train service in several corridors.
  5. Provide more details on 10% transfer assumptions to CT Rail and identify transfer assumptions in Boston to NEC service and the Downeaster.
  6. In funding options, note that FRA Federal-State Partnership for State of Good Repair Program is generally only available for use on publicly-owned assets and those not in a State of Good Repair.
  7. In funding options, note that the BUILD grants program operates at the agency level and is not specific to any U.S. DOT administration (FTA, FRA or FHWA).

Steve Strauss
NYS Council Representative – Rail Passengers Association