» Comments for the record in the Access to the Regions Core/Tunnel SDEIS

Comments Submitted by Ross B. Capon, Executive Director, National Association of Railroad Passengers
April 28, 2008

As a follow up to the comments which I submitted at the April 1 New York City hearing, the most desirable outcome is Alternative G, that is, new tunnels leading to New York Penn Station (NYP) and tracks continuing east to connect with tracks at Grand Central Terminal (GCT).

Our fallback position is to connect the new tunnels with NYP, as contemplated by New Jersey Transit until about a year ago.

We ask FTA to do the following:

1.    Take whatever steps are necessary to achieve, however belatedly, release to the public of the full 2003 ARC Major Investment Study Phase 3 Report(s).  This was a key point in our January 11 meeting with FTA staff in Washington, and in my more recent telephone conversations with FTA officials including the regional administrator.

It is unacceptable that this project is going forward while the public has still access to only a 31-page Summary Report.  This report and its findings are referred to in the ARC SDEIS to justify dropping an East Side access alternative (Alternative G) from EIS consideration, that is, to alter the largest expenditure of capital funds in the modern era of transportation investments in the Tri-state region.  Yet the justifications are unsubstantiated claims without provision of supporting documentation to the public.  Consequently, release of this report, and provision of time for the public to review it, is necessary for the current EIS process to be valid. 

2.    Extend the ARC SDEIS filing date at least 30 days after release of the above-referenced report, to allow time for meaningful public review of the material.

3.    Conduct ARC Regional Citizens’ Liaison Committee (RCLC) meeting where meaningful “citizens’ liaison” occurs, with knowledgeable writers/sources of report(s) available to answer questions from the public.

4.    Reach out to the Federal Railroad Administrator to develop a comprehensive federal picture of ARC & Portal Bridge Capacity Enhancement Projects.  Segmentation of ARC into two separate projects in 2004, whatever its merits, obscured alternatives, total costs, funding requirements and federal understanding of Amtrak impacts.

5.    Identify senior FTA representative(s) and an FRA liaison official to meet with rail advocate representatives to hear and discuss:

a.    Fatal flaws of extending 34th St deep cavern station to the East Side.

b.    DEIS NYP connection plus NYP-GCT connection as solution to East Side service.

c.    Overstatement of ARC Build Alternative benefits by systematic understatement of No Build Alternative capacity and ridership and avoidance of $1.4 billion in costs by segmentation of ARC components west of Secaucus Station.

d.    Negative impact of ARC SDEIS alternative on Amtrak, specifically the loss of the NYP connection and Empire Corridor access to NYP Tracks 9-18.

FTA cannot fulfill its role as a careful, conscientious custodian of federal funds, unless senior officials receive complete information on this project and the publicly stated ultimate scope of East Side access.  The NJ Transit executive director has stated that no current planning is underway to develop a plan for future East Side Access.  The ARC SDEIS gives no assurance that future East Side access is practicable – the only reference to future East Side access in the SDEIS, “would not preclude connections to east Manhattan transit options or facilities”, is unsubstantiated and is no proof that such a connection can be reasonably afforded, constructed and reliably operated.

6.    Do not complete Record of Decision (ROD) on NJ Transit’s deep cavern plan described in ARC SDEIS – this project alternative is fatally flawed regarding access to the East Side. 

7.    Move as quickly as possible towards Record of Decision on direct track connection from the ARC tunnels to NYP described and evaluated in ARC DEIS, dropping the deep cavern component of that plan.

8.    Fully fund planning and EIS for a direct track connection between NYP and GCT, beginning with work done in ARC MIS, with full participation by MTA, Amtrak and FRA – puts ARC additional capacity on the East Side where customers need it; fulfills ARC goal of best possible Midtown access; provides West Side access for Metro-North customers; maximizes Amtrak’s access to largest US office market; & creates multiple opportunities for improved regional service & connections. 

9.    As an “early action” effort, fund an “interoperability” demonstration plan that initiates inter-railroad thru-running at NYP before the end of the current administration, bringing state transit agencies together to work out details of common equipment designs and marketing plan – best way to work out all actions necessary to successfully operate the NYP-GCT connection.

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