Comments on Caltrain electrification EIR, May 2004
[BayRail Alliance letterhead]
May 25, 2004
Attn: Carol Wolf, Program Manager
Caltrain Electrification Program
P.O. Box 3006
San Carlos CA 94070-1306
RE: Electrification DEIR Comments
Dear Ms. Wolf:
We are writing to submit our comments on the draft Caltrain Electrification
Environmental Impact Report. We have strongly supported the Electrification
project for many years and are pleased to see it move forward.
We feel that it is important for the electrification program to acknowledge
related benefits that could be made possible by the program. These include
reduced dwell time at stations, intangibles such as a modern and attractive
image, new and modernized equipment with amenities such as laptop outlets
that appeal to commuters, greater reliability and operational benefits for
increasingly frequent service.
We'd like to see the following items addressed in the final EIR:
- Analysis of costs of electrification to Tamien instead of to Gilroy.
Electrifying all the way to Gilroy doesn't make sense, until a much greater
frequency of train service becomes standard on the Gilroy extension. Even
VTA board chair Don Gage, who represents southern Santa Clara County and
Gilroy, is on record as saying he doesn't think electrifying to Gilroy makes
sense. Gage feels that increased service levels would better serve his
constituents and would rather see electrification monies for the Gilroy
extension directed to other infrastructure improvements to permit greater
frequency of service to Gilroy. Gilroy extension service operations could
perhaps be combined with future planned diesel service to Salinas.
- Analysis of feasibility of electrifying to Palo Alto. Given the reticence
of VTA to fund Caltrain electrification until they have come to some
resolution over the BART to San Jose project, it may be necessary to
terminate electrification in Palo Alto. We'd like the EIR to examine the
costs of this.
- Fuel pricing and savings. Please include a discussion of the expected
future volatility of the price of diesel fuel vs. electricity, and whether
electrification has the potential to provide large operational cost savings
as a result.
- Time savings possible with EMUs and total passenger car replacement. The
time savings benefit of the electrification project is presented as being
the same regardless of the type of equipment chosen. However, we feel that
dwell time at stations could be reduced considerably if new equipment
provided level boarding and more doors, resulting in a significant benefit.
The time savings, coupled with the added speed provided by electrification,
may provide Caltrain with significant additional operational savings. We
would like to see this analyzed in the EIR.
- Operational savings possible with EMUs. We'd like to see a discussion of
the reduced operating costs that may be possible with EMUs vs. electric
locomotives. One advantage of EMUs is greater operational flexibility and
ability to realize savings in operating and maintenance costs from varying
the consist size to match passenger load (such as running shorter trains
during non-peak hours).
- Freight and FRA compliance. We urge you to avoid following the example of
the Northeast Corridor. Please consider whether it would be possible to
obtain an exemption from FRA requirements for Caltrain equipment, which
would permit Caltrain to obtain suitable and proven electrified rolling
stock much more cheaply and competitively.
- FRA does allow temporal separation to permit non-FRA equipment and FRA
compliant equipment to use the same track. Caltrain could explore temporal
separation that many LRT agencies use to separate freight trains and LRTs
along the same tracks. Caltrain should also consider different versions of
separation, such as dedicating one track for freight use at night and
maintain a two-way passenger traffic on another. Given the small amount of
freight traffic on the Caltrain line, the ability to implement technologies,
such as positive train control or automatic train stops, and operating rules
to separate the two types of equipment, we believe a strong case could be
made for the FRA to grant Caltrain an exemption from purchasing
FRA-compliant equipment. This could save Caltrain hundreds of millions of
dollars in operating cost as well as equipment cost.
- Elimination of freight. Would it be possible to eliminate freight service
from the Caltrain line, and what would be the environmental and revenue
impacts? It seems to us that the potential savings that Caltrain could
realize with the ability to purchase non-FRA equipment, and benefits from
the ability to provide platforms designed for level boarding, would greatly
outweigh the revenue loss from eliminating freight.
- Grade separations. A common question that has come up is whether
electrification will increase the cost of future grade separations. We
believe that most of the costs of electrification are due to the substations
and equipment, rather than the actual wiring at grade crossings. We don't
think that electrification will add significantly to the cost of future
grade separations, but please address this issue in the EIR.
- Grade separations at 16th Street and Common Street in San Francisco. We
are concerned that grade separations are required at these intersections to
avoid disasterous interference from planned Muni trolley operations.
- Substations. Given additional miles of electrified line on multiple
tracks, as Caltrain expands to a quadruple-track line and increases service,
will additional substations be necessary?
- Electrification and HSR. There is a great deal of confusion in the
community over the relationship between these two projects. Some seem to
have the impression that if we wait long enough HSR will electrify the line
for Caltrain, and that to do so earlier would be a "waste". We think it
would be helpful for you to discuss these issues in the EIR. We'd like to
point out that the complete operating/business model for California HSR is
not determined yet. One business model may be for an electrified Caltrain
line to rent out access to the corridor to HSR in return for revenue. In
Japan, HSR makes money and subsidizes over a dozen commuter/feeder lines.
- Growth impacts. We feel that electrification will encourage more
residential development near stations, since noise and air pollution impacts
will be greatly reduced, and that this will result in additional riders for
- Lastly, we'd like to emphasize the huge benefit that electrification will
provide to neighbors of the line. While some are concerned about aesthetic
impacts, we'd like to point out that rarely will people be gazing directly
at the lines and that mostly they will be hidden by trees, buildings or
other objects. In our experience, people become oblivious to the presence
of telephone wires, light rail and electrified trolley wires as they blend
into the visual landscape. Also, we feel that the huge reductions in noise
and air pollution that electrification would provide are significant
benefits that should not be overlooked by neighbors.
Thank you for your consideration of these comments. We also urge your
careful attention to the detailed technical comments submitted by
and Michael Kiesling.