Because the Interstate 81 Environmental Impact Statement (EIS) offered no realistic rail alternatives to the many highway widening options studied, RAIL Solution drafted H-1581 calling for a multi-state rail study to assess the feasibility of handling the large freight flows in the I-81 Corridor by rail instead.  Though the National Environmental Policy Act (NEPA) calls for all reasonable alternatives to be studied with equal rigor, this did not happen in the I-81 Tier I EIS.  H-1581 was intended to plug this gap.

H-1581, passed unanimously by the 2006 General Assembly, contained a detailed scope of work intended to bring about a multi-state, intermodal rail feasibility study in the I-81 Corridor. It sought to determine what would be needed to divert up to 60% of the through trucks in Virginia, and to compare such environmental and economic costs with those to add similar freight capacity on the highway. This would give transportation planners a useful basis for making investment trade-offs when and if new capacity were deemed necessary in the Corridor.

Work got underway in late 2006, and over three years later the Department of Rail and Public Transportation has finally issued a Draft Final Report (DFR) titled Feasibility Plan for Maximum Truck to Rail Diversion in Virginia’s I-81 Corridor (the Study). It can be accessed and downloaded at: http://www.drpt.virginia.gov/studies/files/Draft final report.pdf

In the summary paragraphs that follow, RAIL Solution highlights significant points of the Study.

• Because the DFR fails to make the intended comprehensive feasibility evaluation of rail’s capabilities to divert through trucks from I-81 in Virginia, and because it strays so far from the detailed scope of work envisaged in the enabling legislation, it is of disappointingly minimal usefulness.

• The DFR does little more than ratify Norfolk Southern’s Crescent Corridor initiative, which is the only alternative studied in detail, and the only one found “feasible”.

• In spite of the title, Feasibility Plan for Maximum Truck to Rail Diversion in Virginia’s I-81 Corridor (the Study), the DFR itself admits that Crescent Corridor will not result in maximum feasible diversion: “Does the NS Crescent Corridor proposal capture all of the trucks that could be feasibly diverted from I-81? No. it does not. This report identifies four other strategies that would address other diversion opportunities.”

• The “other strategies” allude to concepts that could carry all trucks by rail, not just shipping containers that are the focus of the Crescent Corridor proposal. This more versatile approach is called “open-intermodal” or roll-on/roll-off technology.  Though the DFR acknowledges such possibilities, it does not study them and they are all rated only “potentially feasible” or “feasibility unknown”.

• Recommendation #2 of the DFR says that such concepts should be studied: “Investigate other potentially feasible truck to rail diversion strategies.”  Ironically, the DFR fails to pursue the thorough investigation called for by the General Assembly in H-1581, the legislation mandating this Study, that would have addressed precisely such questions.

• Cambridge Systematics’ role as lead contractor on the DFR represents a severe conflict of interest most uncustomary for a provider of professional services.  CS is also Norfolk Southern’s principal contractor for its Crescent Corridor proposal and spearheaded the NS TIGER Grant application to the federal government in support of stimulus funding for Crescent Corridor.  Certain proprietary information from the TIGER Grant application was employed in the DFR by Cambridge Systematics, making verification by the public of this analysis impossible.

• The DFR has improved since earlier February and October, 2009, drafts.  Recognition in the DFR that other rail strategies beyond Crescent Corridor exist with far greater diversion potential, and need to be studied, is an important change.

• Strategies 1 + 2 + 3 + 4 + 5A together show a potential diversion of 54.2% of the long-haul, through trucks from I-81 in Virginia, amounting to 53.3 million trucks through year 2035, almost three times the 22% for Strategy #1, Crescent Corridor alone, which diverts 19.1 million trucks through 2035.

• Another positive finding from the DFR is that truckers’ savings in driver time plus direct fuel costs approximate the railroad’s projected cost of haulage between Knoxville and Harrisburg.  The DFR says this gives some indication of a “good fit” with a trucker’s “out of pocket expense” associated with driving. Cost advantage will shift further to rail as fuel costs increase.

• Instead of pursuing the original research contemplated in H-1581 that would have provided citizens and transportation planners potentially valuable insights into future investment allocation decisions in the Corridor, Cambridge Systematics has pursued over three years of work at taxpayer expense focused on and justifying the NS Crescent Corridor.
  

• H-1581, passed unanimously by the 2006 General Assembly, contained a detailed scope of work intended to bring about a multi-state, intermodal rail feasibility study in the I-81 Corridor.  It sought to determine what would be needed to divert up to 60% of the through trucks in Virginia, and to compare such environmental and economic costs with those to add similar freight capacity on the highway.

• The DFR has been hijacked from a broad and compelling public purpose to suit the narrow corporate interests of NS.  This cheats Virginia’s citizens and taxpayers out of the benefits envisaged when their elected representatives voted these specifications into law in 2006.

• The original H-1581 scope of work needs to be fulfilled before the DFR is accepted by the Commonwealth.  Arbitrary, political maneuvers by Executive Branch agencies should not be permitted to trump the unanimous Legislative Branch mandate of the General Assembly.