Fax and email to Lisa Ives

[PR2k letterhead]

June 15, 2001

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

Dear Ms. Ives:

We at Peninsula Rail 2000 would like to submit the following comments 
pertaining to the Silicon Valley Rapid Transit Corridor Major Investment 
Study.   Our greatest concern is for the assumptions used and alternatives 
considered to be as fair and equitable as possible.


What Market is Being Served?

Rather than drawing lines on a map at random, the study must be very clear 
as to the markets being served.  From where will the bulk of the riders be 
coming from, and where are they headed?   A map that shows the origins and 
destinations of most riders, using assumptions that are plausible ten years 
hence, would be most helpful in evaluating the proposed alternatives.

To give a negative example, a hastily-compiled BART ridership study by VTA 
unveiled last year assumed an enormous buildup of high-density offices 
downtown, with San Jose taking away parking.

"When promoters of bringing BART to San Jose say the $3.8 billion extension 
would remove 78,000 commuters from the roads, they're relying on a 
startling vision of downtown, one that not only fills virtually every inch 
of land in the existing city center but also tears through adjacent 
residential neighborhoods to make room for more high-rise growth.

It's a vision that would add 176,000 workers to today's modest downtown of 
30,000 employees. Workers filling hundreds of new high-rises would be 
forced to take public transit, since public parking structures would be 
eliminated, and future office buildings would be constructed without
garages."  - From an Oct. 12 front-page article in the San Jose Mercury 
News


The VTA study assumed the downtown residential population will soon be 30 
times bigger than today.  Yet, given that the City of San Jose is currently 
contemplating adding more large parking structures, not removing them; that 
the study assumed a rate of growth that is nothing short of phenomenal; and 
that there is enormous resistance by downtown residents to such a pattern 
of growth, the assumptions used in that study might be considered 
fraudulent.  Reasonable assumptions must be used to predict future travel 
demand in the MIS.

To date, the vast majority of commuters in the Fremont-South Bay Corridor 
are headed to the "Golden Triangle" area of the Silicon Valley, centered in 
the Sunnyvale/Santa Clara area, with many also headed to Mountain View, 
Cupertino, Palo Alto, and Menlo Park. We suspect that the Gilroy/Morgan 
Hill/Blossom Hill to Fremont commute will also continue to grow in both 
directions.  Such data would help evaluate the ridership potential, for 
example, of a Fremont-Gilroy conventional rail line.

It is our understanding that an origin-destination study was recently 
completed by VTA, although the results have not been publicized.  The 
results of such a study should be publicized in conjunction with the MIS to 
assist the public in evaluating the transit alignments under consideration.


What Assumptions Are Being Made?

Ridership projections must take into account improvements in related 
corridors and services that are being planned by other agencies in this 
study area, such as
Planned increases in ACE service
Planned Dumbarton Rail service
Caltrans and Amtrak's California Passenger Rail System 20-Year Improvement 
Plan, which calls for upgrading the Capitol Corridor from San Jose to 
Sacramento to 125 mph half-hour electrified service.
Planned Capitol Corridor stop at the Santa Clara Caltrain station
Planned electrification of the Caltrain line and operation of a "Baby 
Bullet" express service

Other assumptions that will affect ridership and overall project benefits 
and costs, which must be clearly spelled out, include

Fares assumed for each mode
Frequency of operations for each mode
Potential funding sources


Questions that must be answered about the BART options include:

Who will own the BART trains that run on the extension?
If Santa Clara County owns them, will these trains be deployed throughout 
the BART system?  If not, how will BART keep track of the operation of 
these?
If Santa Clara County won't own the trains that run on the extension, how 
will the operating and maintenance costs be split with the BART counties?
What buy-in fees will Santa Clara County need to pay to join the BART 
system?
Because San Mateo County is not an official "BART" county paying property 
taxes for BART, fares for stations along the Colma extension are 
significantly higher than for other stations in the BART system.  Can we 
expect that fares for Santa Clara County stations will similarly be 
expensive?
If costs are higher than anticipated, will some stations be eliminated, and 
if so, which ones?
If costs are higher than anticipated, will the number of trains purchased 
be reduced (as is the case with the BART-SFO-Millbrae extension), hence 
providing less frequent service than originally promised?
If BART is in place, will existing areas that now have through bus service 
to other parts of the county be altered to provide short feeder service to 
BART stations? Will that require more bus riders to transfer and pay 
additional fares?
Since the BART capital funds are planned to come from the Measure A sales 
tax, if the BART project results in cost overruns, will there be any 
protection for other projects so that their funds won't be taken away for 
BART?

VTA should prepare a segment-by-segment ridership projection and cost 
effectiveness analysis for the BART options.


Need Apples-to-Apples Comparison of Routes

Alignments need to be as comparable as possible.  Ideally, you should have 
a matrix showing each combination of technology and alignment.  For 
example, you should include BART on the Alviso route as part of this 
matrix.  In some cases, a particular combination of technologies and routes 
is not feasible due to technical or environmental difficulties.  This could 
be simply indicated in the matrix with an explanation.  Otherwise, the 
combinations of routes and technologies studied should be as comparable as 
possible.

For example, you show BART to Santa Clara, but not LRT to Santa Clara.  LRT 
and conventional rail alignments should have an equivalent connection to 
Santa Clara.
If downtown San Jose is expected to add significant ridership, then LRT and 
conventional rail alignments should have a similar subterranean route to 
BART through downtown San Jose with several stops, instead of just one stop 
at San Jose Diridon station. Conversely, a BART route that has just one 
stop in San Jose should be examined.
For BART, consider a combination of BART to Milpitas connecting to other 
modes.  Currently you have BART as all or nothing.  VTA should prepare a 
segment-by-segment analysis of the route costs and benefits.
Please also consider routing BART and other modes directly to the San Jose 
Airport from Milpitas (perhaps along Trimble.).  The Airport People Mover 
should be considered part of the SVRTC.
Similar tunneling, grade separations, and stations should be considered for 
the light rail, conventional heavy rail, and BART alternatives.

This is not to say that particular technologies should not take advantage 
of the unique characteristics from which they derive a particular benefit. 
 For example, light rail, due to its typically lower speeds and cheaper 
stations, commonly has stations more closely spaced together than heavy 
rail stations.   LRT alignments in this MIS study should accordingly have 
additional intermediate stops where additional and significant ridership 
demand may exist, with express trains running on a third or fourth track 
along major portions of the route where the right-of-way is wide enough. 
 To give another example, express buses are among the most flexible and 
inexpensive of these technologies, and warrants multiple branches to the 
Silicon Valley area to serve multiple job centers.


Need Apples-to-Apples Comparison of Technologies and Frequencies

VTA should assume comparable headways for each technology.   At Grand 
Central Station in New York, for example, buses depart every 10 seconds. 
 In the case of the SVRTC, express buses or alternatively, Bus Rapid 
Transit, for example, should run every 5-7 minutes during peak hours and 
1/2 hour during off-peak hours, with additional service at least every 
30-60 minutes at night and on weekends.

The parameters for the commuter rail option that you outline greatly 
concern us.  The train size that you cite is very low and is not even 
typical of Caltrain and ACE operations.  Maximum speed of 90 mph and train 
length of up to 10 cars per train, are more common for trains of this type. 
 Frequent headways of every 7-15 minutes during peak hours and every 1/2 
hour during the off-peak hours should be used, with service at least every 
30-60 minutes (as demand may warrant) at night and on weekends.


Study Bus Rapid Transit

One technology that you have not considered is Bus Rapid Transit (BRT), a 
form of "rail-on-wheels".  This technology is mentioned in Alternative 2, 
but there seems to be confusion in the technology explanation section 
between standard express buses and BRT.  BRT combines many of the features 
of rail (dedicated guideways/signal preemption, smooth computer-controlled 
acceleration and tracking, rapid subway-style boarding) with the 
flexibility of buses.  The Bay Area Transportation and Land Use Coalition 
recently held a press conference showcasing this technology, for which 
Curitiba, Brazil is well known.  Costs were approximately 5% of the amount 
projected for a subway system serving the same geographic area.  In 
Pittsburgh, the Port Authority of Allegheny County found that BRT (MLK/East 
Side Busway) required operating and maintenance costs of 95 cents per 
passenger, regular buses $2.25 per passenger, and light rail $3.22 per 
passenger.   For more info on this technology contact Seth Schneider at the 
Coalition at 510-740-3104.


Omit Diesel Light Rail

One technology we'd like you to omit is Diesel LRT.  The results for diesel 
LRT would be similar to that of electric LRT, with some significant 
drawbacks.  Given the air pollution that would be generated, the community 
opposition that would be likely to follow, the inability to operate diesel 
trains in subways, and lack of supporting maintenance infrastructure which 
would have to be built at great expense, this technology doesn't make sense 
and doesn't warrant further study.   Eliminating this technology will 
reduce the number of alternatives that need to be considered.


Add Shinn Station

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.


The Total Picture

Extending BART to the Santa Clara/San Jose region is known to be costly; 
the question is, just how much?  Since other alternatives are known to be 
less costly, a greater network of conventional rail, LRT or BRT can be 
provided in conjunction with express buses, local buses, and shuttles for 
the same $4 billion cost or less, in a shorter period of time.  These 
alternatives are likely to produce higher ridership figures if analyzed as 
part of package, rather than as isolated improvements.  Thus, we would like 
the above alternatives to be considered in combination as economics will 
allow.

We at Peninsula Rail 2000 want to see the smartest combination of 
investments in the corridor.  A clear and transparent major investment 
study process will go far to illuminate the most cost-effective and 
beneficial way to proceed.  Thank you for taking these comments into 
consideration.

Sincerely,



Margaret Okuzumi
Executive Director