A map of the Northeast Corridor (credit: SPUI)

Intercity and commuter rail operations in the Northeast Corridor (NEC) of the United States currently move more than 365 million passengers a year, and freight operations move more than 14 million car-miles of freight per year, making the NEC one of the most heavily traveled rail corridors in the world. NEC FUTURE is a comprehensive planning effort launched in 2012 by the U.S. Department of Transportation's Federal Railroad Administration (FRA) to define, evaluate, and prioritize future rail investments in the 457-mile long Northeast Corridor from Washington D.C. to Boston. In 2016, the Federal Railroad Administration is scheduled to release a Tier 1 Final Environmental Impact Statement (EIS) and Service Development Plan (SDP) defining a long-term vision and investment program for the Corridor through 2040. “Tier 1” indicates that the exact footprint of the project has not yet been determined.

The Federal Railroad Administration held public hearings over a two-month period following the November 2015 release of the Tier 1 Draft Environmental Impact Statement. EESI’s Transportation Policy Fellow, Paul Haven, attended the December 16th hearing and his brief, informal comment was picked up by the Washington Post.

On February 16th, EESI submitted comments on the Tier 1 Draft Environmental Impact Statement (EIS) for the Northeast Corridor Future project. The Draft EIS assesses the broad impacts of three alternate investment programs and a "no action plan", on transportation, the economy, the built environment, and natural resources. The intent of the alternatives is to portray a choice between maintaining (alternative 1), growing (alternative 2) or transforming (alternative 3) the role of rail transportation in the corridor. The Federal Railroad Administration will consider all submitted comments, as well as the analysis presented in the Tier 1 Draft EIS and the agency's policy objectives, to identify a preferred investment program.

The Northeast Corridor region generates 20 percent of the nation's Gross Domestic Product and is home to 51 million people (1 in 7 Americans). It includes the seven most densely populated states in the United States and the region’s population is expected to grow to approximately 58 million by 2040. Significant investment in the region's aging and congested transportation network is necessary to sustain economic growth and the mobility of the current and future population. Well planned rail service is the most efficient and environmentally friendly mode of travel. It is not hyperbole to suggest that the future health of the nation's economy and environment hinge on the direction taken as a result of this planning effort. It is in this light that EESI decided to submit the following comment.


Comment submitted by EESI to the Federal Railroad Administration

My comment is quite brief, but in reality is quite complex. An alternatives analysis for the NEC Future is only realistic if it is done in the context of the entire multimodal transportation network, not just the rail network. The analysis must consider what would happen in the rest of the transportation network under each of the NEC Future alternatives.

Looking at the rail mode alone, it is easy to make a statement (section that “Alternative 1 [maintaining] carries the lowest capital cost and greatest net revenue. Alternative 3 [transforming] has the greatest capital cost, and lowest net revenue. This indicates there are diminishing returns in net revenue on the rail investment: as the capital costs increase.” It is easy to say, but it completely ignores reality, and grossly underserves a smart vision for the densely populated Northeast Corridor.

As the region’s population grows, demand for transportation grows, and transportation network capacity will almost certainly increase. If rail capacity does not increase, then road and air capacity will increase – the alternative is economic decline. The question must be this – what is the most efficient way to meet increasing transportation demand of a growing population? Each alternative should bear the cost of the impact on other modes’ capacity. Alternative 1 should bear the cost of increasing roadway and airport capacity to meet increasing demand, since rail capacity increases will be insufficient to meet the demand. For example, how much would it cost to double-deck I-95 and the New Jersey Turnpike? How much would significantly expanding existing airports and building new airports cost?

In addition to uncovering the real cost of the NEC Future alternatives, this approach leads to consideration of each alternative’s environmental impacts across all modes. Those impacts include not only direct use of the land needed for the transportation facilities, but also the land use impacts of expanding each particular mode. Expanding rail capacity moves more people from city center to city center, supporting efficient community development. Expanding highway capacity results in sprawl, and the inherent higher rate of spending for infrastructure that such development inevitably requires. Concurrently, rail and urbanization reduce emissions from the transportation sector, directly because modern passenger rail is powered by electricity, while ubiquitous electrification of auto and air transportation are still aspirations, decades behind rail.

I would submit that anything less than the type of alternatives analysis I am suggesting results in discounting of rail’s positive values, and may perhaps be the reason why we do not have a robust intercity passenger rail network in the United States, as opposed to most developed nations. The NEC Future project is an opportunity to move our thought process forward, do something more holistically, allowing the nation to reap enormous benefits in the long term if we manage to seize that opportunity.

Thank you for the opportunity to comment, and for moving the nation forward with the NEC Future project.

Best Regards,

Paul Haven

PS – Please do NOT confine consideration of my comment to the section I’ve quoted, my comment applies to the entire document. There are many, many examples throughout the document where it is clear that the analysis falls short of the standard I am suggesting. I am happy to provide much more detail if that would be helpful.