Comments on today’s Rail Vision decision by the MBTA board

I don’t usually write blog posts with my comments before the MBTA board, but after today’s momentous decision, with which I mostly agree, I wanted to memorialize my own comments in a more public place than the video replay of the meeting. I could not stay for the whole meeting due to a medical appointment, so I have not done a recap of the excellent comments made by other speakers nor the deliberations of the board, about which you have already read. After the meeting, I sent additional comments to the board by email, along with a copy for the record of my spoken remarks as originally written, as is my usual practice. (I still have no idea where the actual public record of written comments to the board actually ends up — I should ask Owen Kane in person because there are occasionally other people presenting written testimony and I want to know what they’re up to.)

My spoken comments, as prepared

Spoken comments are limited to two minutes, unless you’re a politician, so I had to pick and choose my points carefully — otherwise I would still be talking.

Today you will vote on a preliminary direction for the Rail Vision program. I want to emphasize that there are significant things the board can do, in the time it has left, to move towards the transformative change that commuters are demanding.

First, you need to define priorities for the lines to be upgraded. A full transformation will take a substantial length of time, but different lines present different engineering and operational challenges; you need to FILL THE PIPELINE WITH PROJECTS that will deliver meaningful improvements to commuters in the short term while longer-term projects are in design and construction phases. I believe most advocates are agreed that the Providence and Fairmount lines should proceed first, because they are the easiest, followed by Worcester, but more difficult lines like the Eastern Route need to enter design and permitting right away so that they can be ready to go soon after in sequence.

Second, you need to open a study directly comparing an Orange Line Extension to Regional Rail on the Needham Line. This was out of scope for Rail Vision, but the investments required are both very similar and in substantial conflict — this is a question that needs to be resolved now. Both alternatives need to be considered in their effects on the bus network in Roslindale and West Roxbury.

Third, start building full high platforms now, on a line-by-line basis, rather than the piecemeal approach taken heretofore. Use the line priority list to ensure that construction happens at the right time.

Fourth and finally, start procurement for lightweight 80-meter articulated EMUs for the Providence Line NOW — all plausible alternatives include this upgrade, and at $380 million for the full complement of 32, this represents the ONLY large investment needed for a full transformation of the Providence Line.

My additional comments, written after the meeting

I am gratified by the action the board has taken today to move forward with a true transformation of the MBTA’s commuter rail service. While it is not precisely the action I would have taken, I recognize the board’s desire not to overspecify the actions being required of the staff at a time when both financial arrangements and the Authority’s future governance structures are still being debated in the legislature. I further appreciate the substantial effort that the North Shore delegation has put into making the case for the needs of their communities, which have put up with substandard service for far too long. I am copying my state representative on this message and I hope and expect that he will support the bonding authority and new revenue sources required to execute this transformation, as well as the additional procurement flexibility that I have advocated and that the board’s resolution 4 requests. I do believe and expect that, when the staff completes the analysis you have directed, it will support substantial investment in the Worcester Line sooner rather than later.

I am writing at this time, however, to correct a factual claim made by the Secretary at today’s meeting. The Secretary asserted that the only reason to install high-level platforms was for ADA accessibility, and that only the previously established PATI priorities should be considered. This is entirely erroneous.

Building high-level platforms at all stations is entirely justified by the long-term operational improvements that result from such construction. It is the construction of new platforms that then triggers the authority’s obligations to bring stations up to current accessibility standards. These operational benefits accrue only if all of the stations served by a particular line or service have level boarding. Those benefits are:

  1. Elimination of door traps, an unreliable mechanical component which cannot be operated remotely by the train operator.
  2. Eventual (once we have full proof-of-payment fare collection) elimination of conductors and the adoption of rapid-transit staffing practices on the commuter rail system.
  3. The ability to buy standard(*) articulated EMUs rather than yet another custom, MBTA-only vehicle design. This is absolutely essential for a service investment with a 100-year lifetime; we cannot continue lock ourselves into buying inefficient equipment with a minimal global market, little competition, and no economies of scale.
  4. The ability to have more numerous, wider, passenger-operated boarding doors with automatic gap fillers for mobility-impaired users. I would note, in line with Marilyn McNabb’s comments at today’s meeting, that modern, single-level, articulated EMUs have much better provision for wheelchair access than anything the MBTA operates today, with large multipurpose areas for mobility devices, wide central corridors, and numerous fold-up seating positions.
  5. As noted by many commenters, much faster dwell times at stations, particularly when combined with the elimination of bi-level coaches. Faster trip times and faster turn-around times not only benefit current and future riders, but significantly reduce the vehicle requirements necessary to maintain clockface scheduling with current and projected passenger demands.

Because of the network effects — in particular, the ability to use doors without traps as required by any modern EMU — it is absolutely essential that all the stations required by any service be upgraded before the service begins. Given the time required to procure new rolling stock, this is entirely practical, and would provide direct benefits to all riders even before the new service begins.

I share the Chairman’s skepticism about the estimated cost of $100m per station to upgrade the five current low-platform stations on the Providence line, and I strongly suspect that these estimates are being larded up with unrelated costs beyond platform raising and the actually required accessibility improvements. All of these stations have mini-high platforms already and are thus considered “accessible” in the MBTA’s official maps.

I am also concerned by director Shortsleeve’s emphasis on new ridership. Yes, expanding ridership is an important factor to be considered — but improvements for the reliability, comfort, and convenience of the existing ridership must not be overlooked. The MBTA cannot afford to take its current riders for granted, or, as we have seen on bus and rapid transit, they may well decide that the MBTA is not adequately serving their needs and take their jobs and economic activity elsewhere.

My estimate of 32 cars and $380 million for the Providence Line, as given in my original testimony, is based on schedule simulations indicating that 30 80-meter vehicles are required to give every current passenger a seat, with a padded trip time of 48 minutes each way, 8 three-EMU trains per hour during the peak, and a 7% spare ratio (as appropriate for the much more reliable EMU vs. the 20% that Rail Vision assumed). Service within Rhode Island would require an additional four vehicles, but that would be sufficient to operate a full-time Westerly-to-Pawtucket shuttle with timed transfers for continuing service to Boston. The cost per EMU of $11.8m is based on the 2016 Helsinki order of 75-meter Stadler FLIRT EMUs, adjusted for currency conversion, inflation, and a slightly longer vehicle to optimally match the MBTA’s standard 800-foot platform length.

(*) Currently, no EMUs are being made with both ACSES for positive train control and 1220mm NEC high platforms, except the heavy and inefficient Metro-North type M8, but all major EMU manufacturers are offering designs that would easily accommodate both of these requirements without requiring substantial redesigns or more than the usual vehicle engineering work that accompanies any procurement, and if we bought such vehicles, there would be an immediate market from other agencies with NEC platform height. While the difference in platform height may seem to be a disadvantage or mitigate against buying a Euro-standard EMU design, it is actually helpful in this case — it’s much easier to alter a 600mm low-floor EMU design to support 1220mm high platforms than the other way around.

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