Letter from PITF to Federal Railroad Administrator about disclosure of grade-crossing cumulative impact in the Environmental Assessment of the Point Defiance Bypass
November 8, 2012
Honorable Joseph Szabo
Federal Railroad Administrator
U.S. Department of Transportation
Washington, DC
Dear
Administrator Szabo:
In
re: Point Defiance Bypass Project, Washington State, comment period ending
November 9, 2012
I
am a 30 year resident of Washington State with a deep interest in
transportation cost-effectiveness and safety. My profession is public policy
and program analysis, which I now practice independently and as an associate of
several non-profit organizations.
This
letter is a communication from the Public
Interest Transportation Forum, a civic information web site I have been
operating since 1996 at
http://www.bettertransport.info/. Please make this letter part of the
environmental record for the Point Defiance Bypass Project, a track
revision which sets up Amtrak passenger trains between Seattle and Portland to move
through Lakewood, Washington (just south of Tacoma) on a new high-speed
passenger rail corridor at 79 mph, instead of where routed now along the Puget
Sound shoreline. There will be 20 at-grade crossing in the urban area where the
track passes, already used by slower commuter trains.
In
this communication, I'm shining a light on a particular lack of full
disclosure of environmental impacts of these 20 road crossings in the
Environmental Analysis (EA) for the Point Defiance Bypass Project.
This
project was brought to my attention by a journalist’s account published at the
online news site Crosscut, April 20,
2011, "Blowing the whistle on plans to shift Amtrak's route south of
Tacoma" available for reading at
http://crosscut.com/2011/04/20/transportation/20728/Blowing-whistle-on-plans-shift-Amtraks-route-south/. I also noticed
the editorial in the Tacoma News Tribune
on August 20, 2012, “‘We Can't Wait' for rail bypass? Job 1 is to make it safe”
posted at
http://www.thenewstribune.com/2012/08/24/2266511/we-cant-wait-for-rail-bypass-job.html.
Based
on my examination of an unpublished government working document, a spreadsheet that
backs up the grade crossing safety analysis Environmental Analysis, I found that
the new passenger rail corridor set up by this project has been professionally analyzed
to reveal that the Point Defiance track route is forecast to experience
approximately one crash per year at railroad grade crossings along the
corridor. However, this quantitative bottom line implication of the analysis is
not revealed in the EA.
The
Excel spreadsheet I refer to was created by Washington State Department of
Transportation (WSDOT) and sent to me after I requested the detailed analytics
that were applied to the task of predicting future grade crossing accidents at
20 places where the tracks cross roads.
The
spreadsheet calculations of the expected number of annual vehicle-train
accidents are used as justification in the EA for an important conclusion:
Rebuilding of existing busy rail crossings in City of Lakewood and other
jurisdictions to have grade separation of tracks and roadway is not
necessary for safe operation. This conclusion is reached because of the
forecast that crashes at any one crossing are forecast to be rare.
Cumulatively,
however, across all of the crossings, the forecast is more troubling – about
one crash per year. There is no apparent statement in the
published EA document on this important overall, cumulative effect, or if there
is, it’s buried.
The
forecast of about one crash per year along all of the grade crossings in this
corridor is shown by the number 1.2 years “Between Accidents” in cell Y33 in
the Summary worksheet of the referenced spreadsheet provided to me by WSDOT
that I have posted to
http://www.bettertransport.info/pitf/lakewoodspreadsheet.xlsx .
Significantly,
the bottom line “All Crossings” crash forecast numbers produced by WSDOT
describe a cumulative effect that is left off "Exhibit 59. Individual
Crossing Accident Experience Predicted for Year 2030 Conditions" on page
94 of the Transportation Discipline Report in the Environmental Assessment (EA),
a table of numbers copied from the same Summary page of the spreadsheet. Along with the fact that the raw spreadsheet
is not included in the EA as an appendix, the non-reporting of
the
cumulative effect of high speed trains moving through a set of urban at-grade
road crossings is an oversight that should be corrected in the environmental
record.
If
Amtrak passenger trains are asserted to be safe in crossing busy municipal streets
because quantitative analysis implies they are safe, please make sure the
U.S. Government discloses fully what the analysis actually shows.
Respectfully,
John
Niles
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