Letter to Sec. Peter Buttigieg

August 19, 2023

USDOT:  Pete Buttigieg (Cabinet Secretary)
FRA:  Amit Bose, Administrator
FTA:  Nuria Fernandez, Administrator 

To: contactus@fralongdistancerailstudy.org 

Subject: Comment letter on Round 2 on FRA Long-Distance Service Study

The Federal Railroad Administration has twice this year asked for input regarding passenger rail in the United States.  As a nationally recognized rail passenger advocacy organization, RUN answered the request for public comment on the Federal Railroad Administration’s Amtrak Daily Long-Distance Service Study.

 This is a follow up to our March 13, 2023 comment letter on the FRA Long Distance study, which included our recommendations for an enhanced passenger rail system with additional routes and services. We now respond to the second call for additional input to the Conceptual Enhanced Network which the FRA has proposed based upon input received thus far.

To reiterate and clarify our position, RUN advocates on behalf of all riders on rail-based transportation, whether Amtrak or local rail transit. We appreciate the importance of Amtrak in providing mobility throughout most of the nation, and we also advocate for improved connectivity between Amtrak and local rail transit.

Members of RUN have studied the report developed by the FRA which has explained the methodology used to develop the enhanced network, and deeply appreciate the legislative considerations guiding that planned development.  Hopefully this effort will not only enhance connectivity between major cities and regions and will also connect rural and/or less advantaged communities between those cities and within those regions.  Enhanced and expanded routes will result in a true system of interconnected passenger rail routes producing increase ridership as well as developing and increasing local and state economies.  

 Enhanced Network:

For the maximum public benefit of this Long Distance Study, we need the FRA to champion the expansion and improvement of the Amtrak long distance network, after the conclusion of this study process.   

We ask that the FRA prioritize several projects to serve as test cases to prove the merits of this enhanced system.  For the credibility of FRA and Amtrak, we need some near-term wins of “low-hanging fruit” routes that would require minimal new infrastructure. It could be a new route or an improved current route, but improvements needed should be accomplished to demonstrate the effectiveness of enhancements to passenger rail.  We suggest the following restorations of service:

·      Daily service on the Cardinal and Sunset Limited

·      The Desert Wind from Salt Lake City to Los Angeles (with perhaps initial service SLC- Las Vegas)

·      The Pioneer from Seattle and Portland to Salt Lake City via Idaho

·      A new route from Meridian, MS to Dallas/Fort Worth, Texas

·      The Floridian directly connecting the upper Midwest to Florida via Atlanta

·      The Broadway Limited from New York to Chicago

·      The North Coast Hiawatha from Seattle through southern Montana’s major cities to   Chicago 

·      The Rocky Mountain Flyer, connecting El Paso, Albuquerque, Denver, Casper and Helena, MT to Shelby, MT.

Our proposals, if implemented, will allow for this enhanced network carrying many more       travelers to many more destinations to become even more successful.

Following the ‘conceptual-level identification of capacity improvements’ in this Long-Distance study, the FRA needs to subsequently work with host railroads and others on more in-depth engineering studies to itemize and provide cost estimates on infrastructure capital projects needed along each of the proposed new/enhanced/restored corridors.  The current study should recommend a path forward for this work to begin as soon as possible. 

Also worthy of investigation are new policy incentives for host railroad capacity improvement projects  

 Economic and Social Well-Being of Rural Areas, Rural Accessibility:

We are very pleased to see that the study will prioritize rural and disadvantaged communities not served by existing passenger rail network, including tribal lands. 

There are also many urban, suburban and rural residents alike who do not “choose” to live without personally driving their own car. They might be too young or too old to drive, have a disability that does not allow them to drive, or they might not be able to afford to buy, insure and maintain a car. The concept of “Universal Basic Mobility” is gaining popularity. It is idea that all citizens should have a decent range of affordable transport options, regardless of their socioeconomic status, disabilities, or geographic location.

 An expanded nationwide system of regional and intercity passenger rail coordinated with local public transit would enable more urban and rural low-income families to access health care, education, jobs, and community life. It is also true for youth, elders and the disabled who neither can afford a car or no longer want to drive. Expansion of passenger rail service would also improve transportation access and help support local economies in rural communities, cities, suburbs, and Native American reservations.

As part of this study, FRA needs to measure both the public and economic benefits of Long Distance trains, including quantifying (in dollars) both direct and indirect benefits to local economies.

Measures of Effectiveness and Benefits:

 Transportation safety benefits of Long Distance trains-

One important benefit to rural travelers provided by the Amtrak long-distance trains is a safer alternative to driving. Rural residents make up less than 20% of the U.S. population, but account for about half of the total number of traffic fatalities nationwide, due to higher per-capita miles driven (or being a passenger in car for more miles).

The FRA study should estimate the safety benefits (reduced car accidents) of existing and new Amtrak Long Distance train services. 

Environmental and energy efficiency benefits of Long Distance trains-

The FRA study should estimate the environmental benefits (estimates of reduced pollution, fuel consumption compared to driving) of existing and new Amtrak Long Distance train services.  Particularly important is estimation of the reduction of greenhouse gas emissions enabled by Amtrak long-distance train services- both new and existing. 

Equipment:

An essential step for improving Amtrak long distance service is the acquisition of new equipment: there are currently not enough locomotives and passenger cars (the Superliner fleet) in a good state of repair to reliably sustain the existing Amtrak Long Distance Network.  

This FRA study needs to estimate how much new equipment is needed for these routes, and how much service can be supported with refurbishment/repair of existing Long-Distance equipment not-in-service (in storage at Beech Grove yard?).   FRA needs to make specific recommendations to Amtrak on procurement of new Long-Distance equipment, and help find ways to expedite this procurement. 

The FRA study should also investigate maintenance requirements for new Long- Distance services, including possible locations for new Amtrak maintenance facilities. 

FRA study team should engage rail advocacy groups to address passenger comfort in designs for new long-distance Amtrak equipment.  

Congress has recently allocated funding to restore to service the hundreds of cars and locomotives currently out of service for maintenance/overhaul/rebuilding.

Rail passenger advocates using government information sources have concluded that several daily, on-time trains each way on a route are proven to lure and keep people riding the rails.  

We propose building to this several-trains-per-day concept as new rolling stock is manufactured and put into regular service.  By our estimates, approximately 10,000 new passenger cars of various configurations will be required to supply a minimum of six daily trains for each of the current routes as well as the new proposed routes.  We can begin this process by making every passenger train in the US a daily service.

As a side note, this manufacturing base along with the numerous component manufacturers will provide hundreds, if not thousands of new good-paying jobs throughout the United States.  These jobs will, in turn, provide for subsidiary jobs which invariably spring up around the communities in which they are located.

 Crew resources:

 The FRA study needs to examine needs and strategies for hiring, training and retaining crew for Long Distance trains. The Covid relief funds provided by Congress should have enabled Amtrak to maintain its existing crews,  but instead it furloughed personnel.  These layoffs have severely impacted Amtrak’s ability to both crew the trains as well as maintain and repair the equipment needed for the trains, as short as they currently are, to still operate.   

Host railroads:

 Freight train interference/on-time performance.  Freight railroads have been required by law to provide Amtrak with “preference”.  This law is often ignored and as a result passengers suffer as well as the American economy.  Federal legislation is required to hold freight rail companies accountable and to allow Amtrak to defend its legal rights and ensure p=passengers are not unfairly delayed by freight trains.  We would also like to see better co-operation between Amtrak and the host railroads to capture back some of the business which should be hauled by rail.  By doing so, some of the unnecessary truck traffic which has also resulted in a driver shortage and more expensive shipping rates could be relieved.

Sincerely,

Richard Rudolph, Ph.D., Chairman, Rail Users Network 207-776-4961. rrudolph1022@gmail.com

Andrew Albert, Vice Chairman, Rail Users Network aalbertnyc1@gmail.com

Letter to Rep. Sam Graves

June 10, 2023
Representative Sam Graves. US Congress 6th District of Missouri

Dear Representative Sam Graves:

RUN advocates on behalf of all riders on rail-based transportation, whether Amtrak or local rail transit. We appreciate the importance of Amtrak in providing mobility throughout most of the nation, and we also advocate for improved connectivity between Amtrak and local rail transit.
 
Our members, including those who serve on our Board, live in different parts of the country, including along the Northeast Corridor (NEC). We appreciate the mobility provided by Amtrak and the local railroads in that part of the country but, at the same time, we recognize the requirement that the Amtrak Board represent geographically-diverse regions of the country and the riders and potential riders who live in those regions. Throughout its history, RUN has advocated strongly for a robust Amtrak National Network, in addition to improvements in the Northeast.
 
RUN believes that the country outside the Northeast Corridor, which statute defines to include Connecticut, Massachusetts, Rhode Island, New Jersey, New York, Delaware, Maryland, Pennsylvania, and the District of Columbia, is grossly under-represented in terms of Amtrak services and its board members.
 
As such, the Rail Users Network is gravely concerned about the direction the President of the United States is taking in his choices of nominees for the Amtrak Board of Directors. His choices are in direct conflict with the provisions set forth in Public Law 117-58 by the 117th Congress as 49 U.S. Code (USC) 24302.
 
According to 49 U.S. Code § 24302 – Board of Directors, part (C):
8 individuals appointed by the President of the United States, by and with the advice and consent of the Senate, [having the following characteristics]:
1) general business and financial experience, experience or qualifications in transportation, freight and passenger rail transportation, travel, hospitality, cruise line, or passenger air transportation businesses,
2) representatives of employees or users of passenger rail transportation or a State government, at least 1 of whom shall be an individual with a disability (as defined in section 3 of the Americans with Disabilities Act of 1990 (42 U.S.C. 12102)) who has a demonstrated history of, or experience with, accessibility, mobility, and inclusive transportation in passenger rail or commuter rail,
3) rail passenger advocacy,
4) union affiliation and service,
5) military experience, while not required, is a plus, and
6) candidates should reflect opposing political parties.
 
Congress mandated in IIJA that no more than four members of Amtrak’s Board come from the Northeast Corridor (NEC), which the statute defines to include Connecticut, Massachusetts, Rhode Island, New Jersey, New York, Delaware, Maryland, Pennsylvania, and the District of Columbia. Of the six individuals nominated all but one are from the Northeast Corridor, which is in direct violation of this Act which clearly defines Congress’s intent for the Board to represent the entire nation. We agree with Senator Jon Tester, and we want to voice his ask to bring this slate of nominees into compliance with the IIJA requirements.
 
Further, we also believe the Board will be better served by candidates with familiarity with the operations and customer base of Amtrak’s long-distance (LD) routes which are suffering from Amtrak’s concentration on the NEC and the near abandonment of long-distance services. Selection of more regionally diverse candidates would greatly stem the slow dissolution of Amtrak’s LD trains and services.
 
To reiterate, RUN requests that any nominees for Amtrak’s Board of Directors be representative of the entire United States and the services therein to include not only the Northeast Corridor and state- supported corridor services, but also the long-distance trains which establish the nationwide system, thin as it is.
 
Sincerely,
Richard Rudolph, Ph.D., 
Chairman, Rail Users’ Network
211 Ocean Ave, Portland, ME 04103
rrudolph1022@gmail.com 207-776-4961.
The Rail Users Network (RUN) is a 501 (c) (3) tax exempt national organization

Letter to Sec. Peter Buttigieg

August 30, 2022
Pete Buttigieg, U.S. Secretary of Transportation

Dear Secretary Buttigieg:

We are writing on behalf of our members, as well as the millions of Americans who depend on public transportation on a regular basis to travel to work, see relatives, seek medical attention, food and other necessities of life. While we certainly appreciate the funding that Amtrak has received through the passage of the Infrastructure Investment and Jobs Act (IIJA) it appears that Amtrak management is once again setting the stage to further reduce passenger service on its long-distance routes. Currently, the three trains from Chicago to the West Coast are running every day, as well as the Lakeshore Limited to New York and the section of the train to Boston. In the southern part of the country, however, the Silver Meteor remains suspended and the City of New Orleans from New Orleans to Chicago and the Crescent to New York remain on a five-day schedule until October 2.

To make matters worse, Amtrak has been running shorter consists than has been customary despite demand that has exceeded the level from the past two summers and coach passengers are no longer permitted to purchase a meal or even enter the dining car. There are also reports of passenger cars backed up at the Amtrak shops at Beech Grove, Indiana for repairs. A reliable source in rail-blogging circles has reported that Amtrak is considering cutting service again this fall either to five days a week or even to three, on the entire long-distance network.

The meltdown of Amtrak’s service is also affecting state supported routes as well. We have just learned that the Wolverine Service which normally operate between Chicago and Pontiac is cancelled with no alternate transportation provided between August 29 through Friday, September 16, 2022.

We believe that Amtrak board must prioritize and designate already appropriated IIJA funding to fully restore Amtrak long distance service. This must include restoring daily service to all of the long-distance routes, repairing out of service equipment as well as developing a procurement program to replace the aging long-distance fleet and to provide adequate dining car staffing so that coach passengers are able to purchase meals in dining cars.

We also request that these issues are brought to Amtrak’s Board of Directors via your designee, Amit Bose, who serves as the Administrator of the Federal Railroad Administration.

We look forward to your response regarding these matters.

Sincerely,

Richard Rudolph, Ph.D., Chairman, Rail Users Network rrudolph1022@gmail.com

Andrew Albert, Vice Chairman, Rail Users Network aalbertnyc1@gmail.com

RESOLUTION CALLING FOR ELIMINATION OF THE STATUTORY PROVISION THAT PROHIBITS ANY GROWTH OF AMTRAK’S NATIONAL NETWORK

At a meeting of the Board of Directors of the Rail Users’ Network (RUN), held by teleconference on September 25, 2021, the following resolution was adopted unanimously:

WHEREAS Section 201(a)(5)(C) of the Passenger Rail Investment & Improvement Act of 2008 (PRIIA) defines Amtrak’s “national passenger rail system” as “long-distance trains of more than 750 miles between endpoints operated by Amtrak as of the date of enactment of the Passenger Rail Investment and Improvement Act of 2008”; and

By defining Amtrak’s national network in that manner, such provision absolutely prohibits any new trains to be added to the national network, unless they are established as state-supported trains, despite their character as trains serving several states; and

There have never been any trains on routes more than 750 miles long that were successfully established with funding from the states served by such routes in Amtrak’s fifty-year history; and

The statutory provision at issue absolutely precludes any new long-distance trains from being established, as demonstrated by Amtrak’s announced expansion plans between now and 2035; and

No trains in Amtrak’s current network have started service more recently than 1985; and

The current prohibition on expanding Amtrak’s long-distance network serves to preclude any expansion of mobility on that network; and

No corridors operated by Amtrak today, with the exception of the Northeast Corridor (which is defined separately in the PRIIA legislation) and intrastate corridors, are longer than 309 miles; and

There is no statutory process for establishing routes of length between 310 and 750 miles, except for the historically-unsuccessful practice of establishing state-supported routes: and

WHEREAS RUN is dedicated to improving mobility by rail, including on Amtrak; it is hereby

RESOLVED that the Rail Users Network hereby calls for the definition of Amtrak’s national network under PRIIA §201(a)(5)(C) be repealed; and

FURTHER RESOLVED that the above-cited definition to be amended to specify trains on Amtrak’s national network as including all trains on routes running through or operating in more than one state, when the length of such route exceeds 310 miles.

This resolution will be sent to Amtrak, appropriate members of Congress, the U.S. Department of Transportation, and other concerned or interested parties.

          ______________________________

          RICHARD RUDOLPH, Ph.D., Chair