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Rail Passengers Responds to Proposal for NEC Project Inventory

July 27, 2022

The Rail Passengers Association submitted comments this week to the Federal Railroad Administration’s proposal for the establishment of the Northeast Corridor Project Inventory and the Federal-State Partnership for Intercity Passenger Rail Program for Northeast Corridor projects.

By Sean Jeans-Gail

The Rail Passengers Association submitted comments this week to the Federal Railroad Administration’s proposal for the establishment of the Northeast Corridor Project Inventory and the Federal-State Partnership for Intercity Passenger Rail Program for Northeast Corridor projects. Our association believes that, if properly implemented, these critical new programs have the potential to transform intercity passenger rail into the dominant mode of interstate transportation throughout the Northeastern U.S.

Below, we’ve highlighted a few of the key ideas and proposals. You can read our entire submission, along with several other agencies and stakeholder groups, online at the Federal Register.

III. NEC Project Inventory Development: [Rail Passengers Association] is very encouraged to see that the FRA has indicated it will use the CONNECT NEC 2035 (C35) analyses, new information considered in updates to C35, and the NEC Capital Investment Plan to inform the first NEC Project Inventory. The Northeast Corridor Commission has published 15 capital investment plans and documentation of needed Northeast Corridor investments over the past decade, and the iteration of these documents represents thousands of hours of work to obtain the input and acceptance of all 18 members.

To be clear, C35 has many shortcomings. It fails to address many of the governance issues that are holding back cost-effective enhancement of intercity and regional rail service along the NEC—such as the establishment of regional network managers, coordination of schedules, standardization of rollingstock and platform specifications, establishment of through-running at key junctions (just a few of the many opportunities for network optimization). However, there are enough foundational projects identified in C35 to allow for the rapid establishment of an effective NEC Inventory, speeding distribution of funds from the Consolidated Appropriations Act of 2022 and Title VIII of the Bipartisan Infrastructure Law (BIL).

III.A. FRA's Approach to Developing the NEC Project Inventory: Rail Passengers urges that when the FRA is prioritizing Station Projects (Lifecycle Stage: Construction, Final Design, and Project Development) it give greater weight to those projects that provide direct ICPR transportation benefits to passengers. These include, but are not limited to: improved and expanded platforms, improved and expanded access to platforms, in-station passenger facilities, information systems for passengers and train operations, expanded and upgraded approach tracks, and improvements to train yard infrastructure.

We have watched with apprehension as more sweeping—and costly—overhauls have been proposed for train stations located on the NEC. The Union Station Redevelopment Corporation recently released a $10 billion plan for Washington Union Station that includes attached bus facilities, underground parking structures, and accommodations for future air rights development. While these are all nice things to have, Rail Passengersbelieves they are inappropriate recipients for extremely limited federal ICPR funds considering the urgent need to shift travelers off highways and airplanes and onto electrified passenger trains.

IV.A. Publication of NEC Project Inventory and Notice of Funding Opportunity: Rail Passengers is joining our state-level partners in calling for the FRA to publish a greater level of detail in NEC Project Inventory, including: financial plans, budgets, schedules for projects in the Inventory, how the NEC Project Inventory will interface with Amtrak’s investment of National Network capital dollars on NEC projects, and how—if at all—NEC Project Inventory list projects will fund Amtrak and commuter railroads’ annual capital maintenance work. As of now, passenger and public advocates don’t have access to that information, which is unacceptable given the amount of funding that will be required to construct a high-performance U.S. ICPR network. It is of special importance to have a clear understanding of these financials given the political debates surrounding long-distance and State-Supported routes, which see annual capital maintenance costs included in their annual operating budgets as part of track usage payments to host railroads.

Additionally, we applaud FRA’s intention to “simplify the application solicitation [for the NOFO] where possible to both leverage the substantial information included in the NEC Project Inventory and the NEC Commission's Planning Documents, and to reduce application burden on Project Sponsors,” as well as the selection and obligation process. It is imperative that the public see substantial benefits from the new BIL passenger rail—through improvements to ICPR and regional rail services, additional frequencies and lower fares, and the creation of family-wage jobs—before the launch of the next surface transportation reauthorization cycle.

IV.B. Project Selections - Technical capacity: Rail Passengers encourages the FRA to prioritize and incentivize the development of in-house expertise by giving greater weight to Project Sponsors that develop the in-house agency staff needed to provide effective management and oversight. In its 2021 report “Saving Time and Making Cents: A Blueprint for Building Transit Better”, the Eno Center for Transportation observed:

Overburdened and undertrained public agency staff have trouble coordinating environmental review and planning documents, creating discrete and clear procurement plans, writing smart and effective contracts, and ensuring adherence to contract terms during construction. These all lead to problems with litigation, change orders, and delays throughout a project. Project sponsors need to invest in better training and support for front office staff who are responsible for overseeing, monitoring, and managing projects from inclusion to operation. They should also establish small, multidisciplinary teams of high-quality, experienced executives with control over on-the-spot decisions, and enough junior staff to support them. FTA needs to work with project sponsors to more precisely determine their workforce needs for project delivery management and oversight.

By prioritizing applications Project Sponsors that invest the resources to building the state-level capacity to effectively manage ICPR projects—rather than outsourcing that function to engineering firms with insufficient structural incentives to deliver projects on-cost and on-time—the FRA can bring the per-mile cost of domestic ICPR projects closer to what international rail agencies are capable of delivering on a regular basis.