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 MCET Alternatives: Key Differences
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 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].
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
* 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
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.
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