RAIL Solution Comments on Draft Statewide Rail Plan
Lack of Vision.
The Draft Statewide Rail Plan (DSRP) manifests a lack of vision and long-term planning. Instead it focuses on specific "narrowly defined" projects that can be recommended for funding over the next six years. The document comes across as timid and tentative. RAIL Solution recommends that the Statewide Rail Plan start with an intense public visioning effort crafted to define what we need rail service, both passenger and freight, to look like in the Commonwealth in the decades ahead.
This should include how we are going to ensure the mobility of goods and people in the future, when oil is no longer abundant, affordable or even available. Railroads are the key, because they are readily electrified. By substituting domestically generated electricity for imported oil, Virginia can ensure its own energy and transportation future. If we do not do so, Virginia will continue to fall behind other states and nations where rail development is proceeding rapidly.
Railroads are more energy efficient, safer, less polluting, including CO2 and greenhouse gas emissions, and have a far more limited footprint on the land. Tell the story. Set the goals. The vision needs to generate excitement and buy-in, which in turn generates funding. The current gas crisis, accompanied by growing concerns over global warming, have made the public more receptive and demanding than ever before to non-highway alternatives. Vehicle miles traveled have dropped sharply on a year over year basis. As a state, and as a nation, we need to refocus from adding ever more highways, during the Eisenhower Interstate Era, to maintaining what we have and redeploying our infrastructure capital investments to rail.
With such a bold Virginia blueprint before us, everyone would know where we’re trying to go and what it will take to get there. The planning and achievement of the long-term goals can be subdivided into project steps, six-year horizons, or whatever, for funding and construction. In this way it would be possible to judge each proposed project against the long-term goals and select and promote those most congruent with our identified objectives.
Muddled Thinking About Funding
At the outset the DSRP claims to focus on projects. Funding and implementation plans are to follow in the Rail Action Plan in September. This distinction seems well intentioned. Project concepts should not be constrained by funding. Nevertheless, the DSRP is hampered throughout by assumptions of lack of rail funding. This results in consistent exclusion of projects or options that it dismisses as too expensive. For example, this statement from p. 42 that the cost of right of way and rail make "it cost prohibitive to construct dedicated commuter nfrastructure." A few pages later "the high capital cost associated with high speed rail systems" is cited as a reason they are not pursued in the Commonwealth. On p. 86 we read about barriers "given the costs of projects and limited public funding available…" Cost compared with what? Highways? Doing nothing?
RAIL Solution suggests that cost is a totally inappropriate screening criterion with no further reference. Would Virginia’s Interstate Highways ever have been built if we had begun the planning process by excluding options because they were more expensive than the current highway outlays or because funding had not yet been identified? Figure 5-1 on p. 8l even projects the current anemic Virginia funding levels for rail on out through 2035. How is this helpful or appropriate?
As a result, the completion estimates for the projects shown are unduly pessimistic. For example, the Alexandria to Manassas rail improvements on p. 69 are targeted for completion in 2014. $8.25 million of routine track and signal upgrading work need not take six years to complete. Project schedules should be recast and shown based on X years from full funding. That way we can know which ones can be completed in a year or two. They might well be funded first so benefits can begin to be realized sooner.
Dominance of the Class 1 Railroads
The Class I carriers' agenda dominates the projects defined in the DSRP. They have a right to put their hands out and get whatever public funding they can. But RAIL Solution finds it questionable public policy to fund projects for the Class I railroads that they would inevitably have to do themselves anyway. Where is the incremental benefit to the public in that?
The NS Coal Corridor is a good example (p. 58). $12.1 million in state funding is designated along the Route 460 corridor from the coalfields to Norfolk. Justification cited is the rising volume of export coal. Nevertheless, it’s not yet at the record levels experienced in the early 1970s when similar infrastructure was in place, and there is no way NS (or CSX) is not going to spend every dime necessary to move export coal, given its typically high profitability. They can’t risk not doing so. No public funding inducement is necessary.
The Draft Plan suggests that progress on the Trans-Dominion Express passenger route may be forthcoming as a quid pro quo. It would be far cleaner, more transparent, and receptive to the public just to fund the TDX service directly, if that is the goal. Then the whole unsavory specter of subsidizing the profitable railroads and their shareholders is avoided. Realistically that’s where the rub will be anytime public funds are proposed for use to enhance private rail systems.
The Coal Corridor also suffers from the fact that the line to the coalfields and the line to Bristol (the TDX route) are not one and the same. Plus here’s the possibility that even after helping NS with the Coal Corridor, no progress would be made on TDX. All in all, RAIL Solution finds this an inappropriately risky and convoluted way to pursue passenger service improvements.
Where's the Public's List?
Projects proposed for consideration under the DSRP are industry projects associated with the Class I railroads, 10 shortline railroads, Amtrak, VRE, and the Port of Hampton Roads. The public is conspicuously underrepresented here. In some cases the projects may result in public benefit in excess of public cost, but maybe not. And might there be other more beneficial projects the public could suggest that have not been brought forward in one of the industry categories? How would those get considered, ranked, and evaluated along with the industry projects?
RAIL Solution finds the lack of such a mechanism to be a major failing of the DSRP. Industry interests, and the public interest, are often not congruent. For example, the public in the I-81 Corridor has suggested a number of rail options for evaluation, some with considerably more potential benefit to Virginia than the NS Crescent Corridor initiative. An "I-81 Freight Rail Study" has been ongoing for several years because of strong grassroots support, yet it is totally eclipsed by the NS Crescent Corridor proposal.
We need to be scrupulously careful that any rail projects are first and foremost driven by what the public needs and wants, especially where public dollars are to be invested. Public benefit must exceed public cost. And projects proposed by the public deserve a full and fair place in the list.
Rail Action Plan
RAIL Solution supports a fully-funded Rail Action Plan (the next step in implementation of the Statewide Rail Plan). We strongly reject the notion that localities need to provide much of the funding for intercity passenger rail. That model may work for commuter rail such as VRE, but it is totally impractical for long distance routes. How many Interstate Highways would have been built if work had to await the buy-in and financial support of each community along the route?
RAIL Solution recommends that the Rail Action Plan promote several key improvements to the Rail Enhancement Fund [§33.1-22.214.171.124]. Currently the fund supplies rail assistance with a 30% private sector match. Most funding has gone to the major Class I railroads in the state because they are the ones with the match capability. But many worthy projects cannot currently be undertaken because of this limitation, because the public has no pool of funds to tap for a 30% match.
1. Allow passenger rail projects to be considered where the 30% match comes from the fares collected when the service starts. Justification: Currently passenger projects have to be pursued in a very circuitous fashion. Aide has to go to the Class I carrier involved, with DRPT hoping to exact a quid pro quo concession from the Class I carrier to support the passenger project. It would be far more transparent and expeditious to be able to target REF money to the passenger projects directly.
2. Allow the state's funds available in the Rail Enhancement Fund to be used as Virginia's match for federal rail funding. Justification: This leverages considerably the total dollars available for rail in the state. There really is no downside to this, yet legislation to do it failed to pass the General Assembly last year. Congress has passed HB 6003, and there is companion legislation on the Senate side, to increase greatly the federal funding available to states for rail. We need to get Virginia in a posture to be able to take down as much of these funds as possible.