SMART Scoping Reqmts 

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Marin Citizens for Effective Transportation

² P.O. Box 6036 ² San Rafael, Ca 94903

Comparison between SMART Alternatives and Marin Citizens for Effective Transportation (MCET) Alternatives: Key Differences:

 

Issue

SMART

MCET

Comment

1.HOV Lane Construction Costs

Allocates HOV lane construction costs to express bus alternative.

HOV lane completion part of TSM.  Costs irrelevant to analysis.

HOV lanes are likely to be completed in 10 to 15 yrs.  Capital cost has nothing to do with either alternative, because the completion is independent of either investments in rail or express buses.

2. Definition and Description of Express Bus Alternative

No difference between SMART’s TSM and Express Bus alternatives other than HOV lane completion.  Includes assumption that buses terminate at Larkspur Ferry.  No expansion of express buses into SF or south of San Rafael.

Express bus alternative designed to answer the question: how much would it cost to provide same ridership as rail?  A significant increase in express bus routes and frequencies will be required.   Buses travel to SF. 

How can a significant investment in express buses be considered without analyzing how many riders a significant increase in bus frequencies and routes would generate.  This is a key issue.  Bus routes and frequencies should be specified to generate an equivalent amount of ridership as train and then costs compared.

3. 

Transportation System Management, (TSM) Alternative(s)

Assumes significant expansion of ferry service and local and intercounty bus routes.  SMART has only one TSM alternative

MCET proposes four TSM alternatives, two with completed HOV lanes, two without, with or without local sales tax funding for expanded local transit

SMART assumes a doubling of ferry service and more services than could be financed even if a local sales tax increase were passed.  MCET "moderate build" is based on service that  could be financed with sales tax to expand local transit.

4. Supportive Rail infrastructure (ferries and bus shuttles)

SMART buries these costs in a TSM alternative that is improbable and includes too much investment.

MCET proposal allocates bus shuttle costs and any required expansion in ferry services to the rail alternatives.

By including significant expansion of the ferry and local bus infrastructure in the TSM alternative, costs that should be allocated to the rail will not be captured.

5. Analysis of Rail ridership with completed HOV

SMART doesn’t include it

MCET proposal will capture effects by including HOV lanes in TSM alternatives.

How is the public to know how the completion of the HOV lanes will impact rail ridership if SMART doesn’t analyze the question?

  

SMART District Board Members/Ms. Lillian Hames                                                                                                            September 15, 2003

SMART

520 Mendocino Ave.

Suite 240

Santa Rosa, CA  95401

 

Dear Board Members and Ms. Hames:

 

Thank you for the opportunity to comment on the “Alternatives Description” provided to us by email.  Our detailed comments are below.   To fully understand our comments requires a review of the attached matrices (see Matrix 1, Matrix 2, and a comparison below) which we developed by following the examples on the FTA website.   We  recommend you use the matrix format to communicate what your final alternatives are.   

 

As all of you are aware, before a major public investment in commuter rail is  undertaken, SMART needs to provide information on whether such an investment can be justified on an economic basis.  This is, in part, achieved by analyzing the proposed rail costs and benefits, broadly defined.   This is an element of the analysis required by the FTA to obtain “New Starts” funding and we agree with the requirement.

 

A critical component of analyzing the costs and benefits of a proposed major public investment in commuter rail, and one that is also required by the FTA, is an alternatives analysis.  In turn, a critical component of preparing an alternatives analysis is to specify and define the alternatives to the proposed investment in commuter rail, which SMART has done in draft form. 

 

Unfortunately, based on our analysis of the detailed assumptions provided, SMART has made several errors which we believe will distort the analysis required by the FTA and mislead the public on the costs and benefits of the rail versus express bus alternatives.  These errors are as follows: 

 

1.      SMART has incorrectly specified the Transportation System Management (TSM) alternative.  As indicated in Attachment A, we believe a minimum of four TSM alternatives are required to fully understand and account for the costs and benefits of the train vs. express bus alternatives.  A review of our proposed TSM alternatives shows that none of our proposed alternatives matches SMART’s proposed single TSM alternative because we believe SMART’s TSM alternative is unrealistic and poorly defined[1][1]

  • SMART states that the TSM alternative assumes a doubling of existing ferry service in SMART’s TSM alternative.  We are unaware of any planning document that supports the doubling of service.  The WTA states the Larkspur ferry ridership goes from 5,000 to 6,576 riders per day between 2000 and 2025[2][2]
  • In its TSM alternative, SMART describes public transportation systems as specified in the “Moving Forward: A 25-year Transportation Vision for Marin County”, refereed to as the Vision. This document describes many different transit modes that were studied separately.  The vision is a $1.3 billion wish list with no fiscal constraints.  The CMA is still struggling to define which projects and modes are worth implementing.  We believe that it is incorrect to define an alternative based on a plan that can not possibly be implemented. 
     

2.      In its specifications of what it labels as the  “Express-Bus-Alternative,”  SMART proposes to include the capital costs of completing the HOV lanes in the Novato Narrows and elsewhere in Sonoma County, but does not include these costs in the rail alternatives. 

·        We believe it is misleading to include the HOV lane capital costs in any of the major investment alternatives.  The completion of the HOV lanes through the Novato Narrows and elsewhere in Sonoma County and, therefore, the associated capital costs are not dependent on either the train or express bus alternatives occurring. 

·        The HOV lanes will encourage transit usage during peak hours and will enhance capacity and safety during off-peak hours.  Environmental studies for HOV lanes through the Novato Narrows have been started; partial funding started, and the system is part of the RTP.  It will be built.  It is only matter of when.

·        The existence of completed HOV lanes will impact the cost and ridership analyses.  Just as completed HOV lanes will enhance express bus usage, they will also create competition for commuter rail service.   We address this issue by varying this assumption in different TSM alternatives. In Attachment A, the incomplete HOV lanes are assumed TSM alternatives #1.2 and #1.3.  Completed HOV lanes are assumed in TSM alternatives #2.2 and #2.3.

3.      In the SMART draft, there would be no analysis of the impact of completed HOV lanes on rail ridership.  This is an oversight and should be corrected.

We capture this by including the HOV lane completion in the two of the TSM alternatives, which means the rail investment alternatives be analyzed assuming completion of the HOV lanes in our alternatives #1.4 - #1.7.

 

4.      SMART fails to specify a significant increase in express bus service in the corridor in any of its alternatives.   There is no difference in bus routes and frequencies between its TSM and Express Bus alternatives.   Furthermore, the TSM alternative does not specify a sufficiently large increase in express bus routes and frequencies in order for it to be considered to be comparable to the level of service provided by the rail alternative to Larkspur.

 

·        We believe SMART needs to redefine its Express Bus alternative so that it actually represents a major investment alternative.  This requires a significant increase in express routes that serve San Francisco bound commuters as well as employment centers in Marin south of San Rafael.

Ø      SMART limits southbound express bus routes when it proposes that they travel  no farther south than the Larkspur (or San Quentin) ferry terminal.  Since providing trips by rail to one of these terminals implies providing trips for San Francisco  bound commuters, SMART needs to specify an expansion of express bus services for these commuters.

Ø      The official notice in the Federal Register acknowledges that Highway 101 is the primary mode connecting Sonoma and Marin Counties with San Francisco.  SMART recognized the importance of the San Francisco connection by adding an extension to SMART rail to a SF bound ferry.  The Regional Transportation Plan also describes connections to SF. 

Ø      In order to get a fair and impartial comparison between the express bus and rail alternatives, it is necessary to include this important leg of the trip all the way into SF.  SMART needs to study the complete system.  An express bus system in the North Bay would be a logical extension to existing bus service from Sonoma County, through Marin and into San Francisco.  Nowhere has SMART specified a significant expansion in bus routes and frequencies into San Francisco and communities south of San Rafael.  It needs to.

5.      How much additional bus service should be included in the Express Bus alternative?  We believe that the following two criteria should be used to design routes and frequencies:

 

(1)   Express and intercounty bus ridership should approximately match the projected ridership of the rail alternatives

(2)   Routes and frequencies should be chosen to maximize transportation user benefits per dollar invested.  

Ø      By specifying bus routes and frequencies using this guidance, the public will gain a better understanding of the how much the commuter rail vs. express buses cost.  By specifying bus routes and frequencies using this guidance the public will be informed as to whether it is less costly to invest in express buses or commuter rail.

6.      SMART assumes the ferry services will double in its TSM alternative. While we believe it prudent to assume some increase in ferry service is appropriate in two of the TSM alternatives, there may be different levels of ferry service that are needed to support rail passengers.  This additional service level is not relevant to the MCET proposed Express Bus alternative. 

 

7.      SMART’s TSM alternative assumes too high a level of public transit infrastructure.  This is more than would be conceivable even if a local sales tax increase obtained voter approval.  

 

8.      The alternatives analysis needs to be more honest in its Alternatives Analysis about the local political situation and the likelihood that SMART’s proposal will receive local public support.

 

·        The City of Larkspur has stated on multiple occasions that SMART’s proposal for a ferry terminal is not consistent with Larkspur’s General Plan.   Simultaneously, there is significant opposition in the state to closing San Quentin.  As a result, SMART may have no acceptable location for a terminal south of San Rafael.

9.      SMART’s draft incorrectly defines the rail to San Quentin alternative.  There are significant changes in the supporting infrastructure and, therefore the capital costs, associated with moving a ferry terminal from Larkspur to San Quentin.  This infrastructure needs to be specified and its costs included in the alternative.

 

We would be happy to meet with the SMART Board, its staff, or its consultants to discuss these issues at your convenience.  

 

Michael R. Arnold, Ph.D.                                             Joy Dahlgren, Ph.D.

Co-chair MCET                                                           Co-chair MCET

 

 

c.  Congresswoman Lynn Woolsey

Marin County Board of Supervisors

Novato City Council

Mark Prado, Marin Independent Journal

Kerry Benefield, Santa Rosa Press Democrat

Peter Fimrite, San Francisco Chronicle

Leslie Rogers, Regional Administrator, FTA, Region IX

 

Matrix 1 -  HOV lanes between Novato and Petaluma and Elsewhere in Sonoma County  are Constructed in 12 Years

   

Alternative

Name

Service Level Assumptions

 

Highway

Ferry

Buses

Comments

 

Local

IntraCounty

Intercounty

 

1.1

   No Build

Scheduled Projects

Plus HOV lanes

Current Levels

Assumed return to 2001 levels + Additional Services Generated by Revenue Forecasts w/o Sales Tax

Similar to SMART, except HOV lanes completed

 

 

 

TSM Alternative

 

 

1.2

    Low Build w/ HOV

Same as No Build

1.1

Minor increase over current service

Any additional bus services that can be funded without sales tax increase:  focus on 101 congestion reduction

SMART did not specify this TSM Alternative

 

1.3

    Higher Build – w/ HOV

Same as No

Build 1.1

~20% increase over current service

Any additional bus services that can be funded with sales tax increase:  focus on 101 congestion reduction

SMART did not specify this TSM Alternative

 

 

Major Investments

 

 

1.4

    Rail to Larkspur

same as TSMs

Sufficient to service projected rail ridership

Includes bus shuttles to train stations

same as TSMs

Requires a second sales tax increase in higher build TSM

 

1.5

    Rail to San Rafael

same as TSMs

Sufficient to service projected rail ridership

Includes bus shuttles to train stations

same as TSMs

Requires a second sales tax increase in higher build TSM

 

1.6

    Rail to Petaluma

same as TSMs

same as TSMs*

Includes bus shuttles to train stations

same as TSMs

Requires a second sales tax increase in higher build TSM

 

1.7

Rail to San Quentin

Same as Larkspur with additional infrastructure and associated costs from moving terminal from Larkspur to San Quentin

Can only happen if San Quentin closes.  Prison closure costs not part of analysis.

 

1.8

  MCET: Express Bus

same as TSMs

same as TSMs*

same as TSMs

Substantial Expansion:  Design based on matching ridership of rail alternatives 1.4

And 1.6

Requires a second sales tax increase in higher build TSM

 

 

 

 

 

 

 

 

 

 

 

 

*    Since in the two TSM alternatives the assumed ferry and bus services vary, rail and Express bus alternatives may need to be evaluated against each alternative separately to determine the extent to which they impact the evaluation.  In addition, major investments with higher build TSM potentially means voter approval of two sales tax increases: one to support local infrastructure and one for the major investments.


Matrix 2  HOV Lanes are not Completed During the Planning Horizon

 

Alternative

Name

Service Level Assumptions

 

Highway

Ferry

Buses

Comments

 

Local

IntraCounty

Intercounty

 

2.1

   No Build

Scheduled Projects

Current

Assumed return to 2001 levels + Additional Services Generated by Revenue Forecasts w/o Sales Tax

Similar to SMART

 

 

 

TSM Alternatives

 

 

2.2

    Low Build - NO HOV

Same as No

Build 2.1

Minor increase over current service

Any additional bus services that can be funded without sales tax increase:  focus on 101 congestion reduction

SMART did not specify

 

2.3

    Higher Build - NO HOV

Same as No

Build 2.1

~20% increase over current service

Any additional bus services that can be funded with sales tax increase:  focus on 101 congestion reduction

Similar to SMART TSM, except service levels defined by local revenues associated with local sales tax

 

 

Major Investments

 

 

2.4

    Rail to Larkspur

same as TSMs

Sufficient to service projected rail ridership

Includes bus shuttles to trains

same as TSMs

Requires a second sales tax increase in higher build TSM

 

2.5

    Rail to San Rafael

same as TSMs

Sufficient to service projected rail ridership

Includes bus shuttles to trains

same as TSMs

Requires a second sales tax increase in higher build TSM

 

2.6

    Rail to Petaluma

same as TSMs

same as TSMs

Includes bus shuttles to trains

same as TSMs

Requires a second sales tax increase in higher build TSM

 

2.7

Rail to San Quentin

Same as Larkspur with additional costs associated with moving terminal from Larkspur to San Quentin

Can only happen if San Quentin closes.  Closure costs not part of analysis.

 

2.8

MCET   Express Bus

same as TSMs

same as TSMs

same as TSMs

Substantial Expansion:  Design based on matching ridership of rail alternatives 2.4 and 2.6

Requires a second sales tax increase in higher build TSM

 

 

Notes: Since rail ridership is higher and bus ridership is low with HOV lanes not completed, alternative 2.8 is likely to have more bus routes and frequencies to match the rail ridership.  Also, see notes on TSMs for Matrix 1.

 

 

MarinInfo's Requirement's Please include the following in any Evaluation of SMART:-

Any Alternative for rail must include a DIRECT, CORRESPONDING, Bus Alternative.
There MUST be a Bus comparison to the proposed 37 mile SMART alternative.

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ALL Bus Alternatives
must include Sonoma Bus Commuters to San Francisco. The commuters to San Rafael will be considerably "subsidized" by Bus Sharing with them. 
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On any scoping evaluation please address the following alternative:

  On Hwy 101 at San Rafael  -  in One Lane during the morning rush hour - 2,300 vehicles pass thru per hour. One Hwy101 freeway lane "conducts" more than 25,000 vehicles per day. Compare that to the SMART rail prediction of saving a maximum of 1,900 car trips per day.   Put Rapid Bus in that lane and you get 40,000 passengers per day. So you can see how MUCH MORE COST EFFECTIVE investing in the freeway is compared to any rail alternative. Lets not waste our money on rail when spending it on another freeway lane will address our congestion so much more cost-effectively.

Why is another freeway lane not included in the current ALTERNATIVES ?
How else are we going to address the
weekly Sunday Southbound Freeway GRIDLOCK congestion as weekenders return home? (not to mention daily gridlock)
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INCLUDE DATA-BACKED ARGUMENTS AGAINST THE FOLLOWING :-

 

As Hwy101 is mostly thru rural (and where urban relatively easy to expand) it is expected that the freeway lane's cost to be not more than $15 mil. / mile (excluding Novato-Petaluma narrows). This equals $750 mil for 50 miles from San Rafael to Cloverdale. One freeway lane offers  6 times more person-miles per route mile  than rail. Which is $125 mil for the freeway Vs $200 mil for the rail   -  per the same person-miles.

The Novato-Petaluma narrows is currently not freeway and needs to be converted, rail or not. (It includes rebuilding the bridge down to Petaluma and 4 interchanges, $485 mil.). What we should be comparing is the cost of widening the EXISTING freeway V SMART Rail, (other than the Novato-Petaluma stretch).

SMART Rail is to terminate at a ferry. San Francisco has more suburban transit boardings than any other city in the US (Yes, even more than NY). San Francisco has no need of more commuters from Sonoma.
 

Are we going to divert much needed funds away from a FAR MORE
              
Cost Effective way of reducing Traffic Congestion
 to a Rail Alternative that will ADMITTEDLY do nothing to relieve congestion?

There is what might be called a “blind faith” that  transit is the antidote to urban traffic congestion. In reality, however, this view is largely false and leads to unrealistic expectations of transit. Breach of Faith:
Light Rail and Smart Growth in Charlotte

Questions? info@MarinInfo.org