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Fax to Lisa Ives  408-955-9765


October 22, 2001

Lisa Ives
VTA - Planning and Programming, Building B
3331 North First Street
San Jose, CA 95134-1906

RE:  COMMENTS ON LATEST SVRTC MIS EVALUATION OF ALTERNATIVES

Dear Ms. Ives:

It is with great disappointment that we note that the deadline for public 
comment on the latest evaluation of alternatives is apparently today, 
because
this deadline is NOT shown on your website, www.svrtc-vta.org, nor in the 
packet of materials that we received just one week ago at the Oct. 15 
Special Interests Stakeholder Meeting.
Stakeholders who attended the Oct. 15 meeting did NOT receive a 4-page 
attachment that described new alternative 11B, that was apparently 
distributed to some attendees of the public workshops held later in the 
week.

Despite the incomplete information given to us, here are our comments on 
the latest SVRTC alternatives.

No Info on Service Levels

It's not possible for us to make meaningful comparisons of the alternatives 
presented without information on the frequency and capacity of the service 
proposed.  This information was not included, and so we can't evaluate what 
service levels were assumed to produce the numbers in Table 2, "Key 
Evaluation Criteria".  Earlier literature artificially assumed a reduced 
frequency and capacity for conventional rail.  We expressed concerns about 
this but have not had a satisfactory response to date.  We have no way of 
assessing whether the assumed service levels were changed in response to 
our concerns.

We further note that Table 2, "Key Evaluation Criteria" apparently doesn't 
include any ridership or costs associated with any of the "optional" 
stations shown in any of the alternatives.  We request that a table be 
prepared which does include the costs and ridership if the "optional" 
stations are built.

Is it Truly Equitable?

No information is given on the fares assumed for each service.  This makes 
it difficult to assess the presumed farebox recovery of each alternative, 
and how the fare structure might impact low-income persons.


Alternative 5 Must Not Be Truncated in the East San Jose

Alternative 5 must be made to connect to San Jose Diridon station in a 
manner similar to that contemplated for BART.  To artificially truncate it 
in East San Jose artificially deflates its potential ridership and travel 
time savings.  We ask that you extend Alt. 5 to San Jose station, and 
further 1) contemplate direct service to south county, at least as far 
south as Blossom Hill, and 2) contemplate direct service to north county 
along the Caltrain line.

From what we've heard from other sources, we understand that Alt. 11B is a 
crippled version of 11, with many fewer BART cars; and that it assumes BART 
to pay for a greater share for station design, parking, and maintenance 
facilities.   Alternative 11B introduces many technical and operating 
complications.  We feel that if VTA is intent on running its own 
independent system, VTA should give serious thought to running heavy rail 
that would run on VTA tracks to south county, and which is compatible with 
providing increased and direct through-service with Caltrain.
Alternative 3 - Please Explain the Inflated Cost

We're stunned by the grossly inflated capital cost for Alternative 3, and 
we ask for more details.  The cost cited is completely out of line with the 
costs of any proposal that ACE has ever discussed.  Does the VTA figure 
include grade-separating all 41 grade crossing between San Jose and 
Livermore?   If not, which segment is grade-separated?  Does the cost cited 
include quadruple-tracking of the wetlands (when double-tracking may 
suffice)?   We note that ACE is requesting of MTC $121 million for 
substantial track improvements that would permit 8 trains/day, and that the 
ACE board just recently approved funds to study double-tracking of the 
wetlands.

ACE's greatest ridership comes from Pleasanton and Fremont, and ACE used to 
run turnback service to Pleasanton.   Perhaps the VTA alternative should 
consider most trains to originate in Pleasanton on a cost-ridership basis. 
Again, without more details on the level of service and improvements 
assumed in Alternative 3, it's difficult to have any confidence in the 
figure cited.

And finally, once again, we ask that you

Include Shinn Station in the Analysis

For the conventional rail, bus, BRT, and LRT alternatives, please add a 
"transfer only" station in Fremont near Shinn Rd. where BART and the 
regional rail lines cross.  Shinn station would be allow only passengers 
transferring from BART, ACE, or the Capitols to board another transit 
system at that location, and would not require any automobile parking 
facilities.

At the Oct. 15 stakeholders meeting, we were told that VTA would not 
include a possible Shinn station in the MIS unless ACE or Capitols had 
formal plans in progress for such a station.   This argument is specious 
for two reasons: VTA's SVRTC MIS Alt. 3 apparently includes ACE track 
improvements far beyond that ever contemplated by ACE; and ACE, Capitols 
and BART board members have on numerous occasions expressed support for the 
Shinn station concept.

Therefore, we ask that you include the Shinn station in the analysis of 
Alternative 3.

For pictures and a map of the station site in question, see

http://www.acerider.org/images/shinn/list.php

Nits, Appendix D

Intermodal connections is not necessarily a useful criteria--for example, 
is the number less for LRT because it's not intermodal with itself?
Why is "Historic and Archaelogical Sites Affected" considered High for Alt. 
1, Bus on HOV?
Goal 4 numbers don't seem consistent with rankings given

Sincerely,

Margaret Okuzumi
Executive Director

cc: SVRTC PAB