Light Rail Planned for Seattle's Rainier Valley Would be Too Hazardous to Operate, According to Federal Guidelines
by John Niles
Published originally before Seattle's Link Light Rail opened in 2009
18 signalized, un-gated street crossings of the tracks are planned.
Thousands of cars, trucks, and buses will traverse these at-grade crossings daily.
10 additional signalized pedestrian crossings are also planned.
Published schedule in the Environmental Analysis shows 272 trains every weekday, each 190 feet long.
Trains have priority at all crossings.
The map below of the light rail alignment in urban southeast Seattle is from Sound Transit. The two red circled points on the map depict the beginning and end of the alignment of twin train tracks along the median of Martin Luther King Jr. Way.
Each traffic light symbol between the two circled in red, and including the two circled in red, indicates the location of an un-gated at-grade street crossing, that is, a place where a street intersects and crosses the train tracks. There are 18 such crossings. In addition, the little red icon that looks like a person is a signalized pedestrian crossing. There are 10 pedestrian crossings.
The schedule of trains published by Sound Transit indicates that 136 are planned in each direction for weekday service, for a total of 272 in both directions. The maximum speed limit for a train in motion will be 35 miles per hour. The trains will initially consist of two cars, a total of 190 feet in length. Eventually, the trains are intended to be four cars long, 380 feet in total length.
Below, as published by City of Seattle, is a map showing daily vehicle flows on arterials in the Rainier Valley in a recent year. Again, light rail train tracks will be installed by Sound Transit in the median of the street running through the three red-circled intersections plus 15 others between and beyond these three. The greatest danger created by light rail trains in this corridor comes from occasional collisions between light rail trains and motor vehicles or walking pedestrians. A 1999 Environmental Impact Statement forecast such a collision every 12 days on average, based on experience with light rail in other cities.
In May 2002, the Federal Transit Administration (FTA) approved Sound Transit's configuration of tracks shown in the map above, including the vehicle and pedestrian crossings. However, under hazard analysis guidelines issued by the Safety and Security Office of the same FTA, a requirement was placed on Sound Transit to issue a safety certification of all elements of the light rail system to be built. At the time, this certification was required to include demonstrating that the expected number of fatalities per one million operating hours will be one or fewer in order to gain a hazard index rating that is better than 1C. A 1C rating -- meaning the hazard is "catastrophic" and "occasional" -- is designated "unacceptable" under the FTA Guidelines. Given the nationwide record of fatalities caused by light rail trains in the U.S. over the past few years, a safety certification of the alignment design shown in the map above should be impossible to make. However, Sound Transit has certified the design using the undocumented concept that any excess fatalities would be "non chargeable" to the design and operation of the system.
In 2005, as a result of a regulatory change perhaps prompted by PITF's and Seattle Times' probing of Central Link safety certification requirements, FTA removed the requirement to meet a specific quantitative hazard requirement. See this document for the revised rules, which notes on page 36, "Compliance with the MIL-STD 882D or the APTA Manual Hazard Resolution Process is no longer required, though rail transit agencies are encouraged to apply these methods as appropriate."
But in 2004 the quantitative rule still applied. The way in which Sound Transit and FTA thought then about the safety of the light rail tracks in the Rainier Valley was described by The Seattle Times in a article dated April 12, 2004, "Light rail stirs safety worries on MLK Way," by Mike Lindblom, who wrote the following:
QUOTE Light-rail design is typically regulated by the Federal Transit Administration, the same agency that funds the projects and provided a $500 million grant for Sound Transit's $2.44 billion line from Westlake Center to Tukwila.
To win the grant, Sound Transit satisfied the FTA that its trains will cause fewer than one fatal crash every million operating hours, or 131 years for Link, to meet new federal hazard guidelines.
But there's a hitch. According to Sound Transit's Qaasim, the 131 years refers only to "chargeable" accidents that are caused by failures in the trains and signals, as opposed to "nonchargeable" collisions caused by others.
Niles counters that such a methodology amounts to blaming the victim. "Historical evidence proves accidents happen, and there is no reason to design a system to allow it to happen," he said.
"I'm not accusing them of ignoring safety. I'm saying light rail has a problem all over America, and Sound Transit is the latest manifestation of that. Any city that's got light rail in the street is on a path to killing people, and they shouldn't do more of this."
FTA officials declined to be interviewed but said through a spokeswoman's e-mail: "FTA regulations do not refer to a threshold number of collisions that is acceptable. Instead, FTA requires grantees to evaluate their systems to ensure that all potential hazards are mitigated to acceptable levels."
Asked why a plan with so many street crossings is permissible, the FTA reiterated Sound Transit's view that the project will make the road corridor safer. Link's environmental-impact statement, written five years ago, predicted a decline of 44 car wrecks and seven car collisions with bicycles or pedestrians a year. UNQUOTE
There is no documentation available from either Sound Transit or FTA that justifies the claim that the Initial Segment Light Rail will make the Rainier Valley corridor safer. The claim doesn't even make sense. Adding trains to an urban street is an inherent danger.
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