Regional Alliance For Transit
Founded 1992

1000 Union Street, Suite 209
San Francisco, California 94133
Telephone: 415 440-6895
Email: raft@arch21.org

December 22 2003

Debra S. Ritt
Assistant Inspector General for Surface and Maritime Programs
Office of the Inspector General
Office of the Secretary of Transportation
U. S. Department of Transportation
400 Seventh Street, S. W.
Washington DC 20590

project number 04M3003M000; &
San Francisco Bay Area Rapid Transit's two mega-projects

Dear Assistant Inspector General:

From your letter to the Administrator of the Federal Transit Administration we have learned that you will be reviewing, through the mechanism of an audit:

"project documentation to determine whether the alternatives analysis made by applicants weighed viable alternatives and what quantitative measures, such as lowest cost-per-rider, were used in choosing the locally preferred alternative."

We would like to provide you with information relevant to the audit about 1) a fixed-guideway mega project that started revenue service earlier this year, and which is receiving New Starts funds, and 2) a fixed-guideway mega project in the planning stage and under review by the FTA.

A Recently Opened Mega Project
BART to San Francisco Airport is being financed in part with an as yet unfulfilled Full Funding Grant Agreement of $750 million. This fixed guideway began revenue service this past spring. We think knowledge of the history of this project will be instructive to your auditors.

Weighing Viable Alternatives
The Commuter Rail system popularly known today as "Caltrain" began passenger service (as a part of the Southern Pacific lines) in the nineteenth century. Caltrain's passenger service has run past the San Francisco Airport for more than sixty years between San Jose and San Francisco. Caltrain is controlled by a joint powers authority which is separate from BART.

Before the BART to San Francisco Airport EIS was finalized, the alternative of making lower cost improvements to Caltrain was brought to the attention of BART and of our MPO. Two of the proponents of improving Caltrain in lieu of the BART project were members of BART's governing board. The less expensive Caltrain alternative was rejected by BART, perhaps because it was not a "BART" project.

Quantitative Measures
The final EIS is an unusual planning document, in that much of the information about the project alternative that was built and is in revenue service today was not provided to the public or to policy makers before the EIS was approved. This is the result of hurriedly adding the alternative to the draft EIS less than two months before the document was approved by the BART board of directors. It is not possible, using the EIS, to determine expected unlinked passenger trips on the extension or expected new unlinked passenger trips on the extension.

Also included in the EIS is information on "Air Passengers" on public transit as of the year 2010. Long after the mega project has started service, it is estimated to carry 7,200 passengers per day, and rubber tire transit (bus, private vans and shuttles) is estimated to carry 14,800 passengers per day, or more than twice as many as the BART to SFO extension.

It should be noted that San Francisco Airport, before the EIS was certified as "final" by the FTA, already had the most intensive transit usage of any airport in the nation.

The EIS does provide quantitative information in other areas. In the case of travel time between the no build alternative and the BART project alternative, one is able to see that, after investing $750 million in federal funds, and nearly another billion dollars in state and local funds, the transit time between either downtown Oakland or downtown San Francisco and the San Francisco Airport terminals is an identical 61 minutes from Oakland and 44 minutes from San Francisco.

The EIS also includes a "Cost Effectiveness" figure of $26.12 per new rider. At the time the EIS was approved, $26.12 was more than enough to pay for a "Super Shuttle" ride, plus a tip for the driver, from downtown San Francisco to the Airport.

The EIS provides an estimate of the number of transfers between Caltrain and BART at the Millbrae intermodal station. It appears that about 19,400 to 24,100 transfers per day were expected. Recent press articles indicate the actual number is about 1,000 transfers per day, or about 5% of the estimated number.

Lastly, there is an issue with the quantitative analysis of the BART to SFO extension, in that the project was rolled up with three other fixed guideway projects after the EIS was approved. The upshot is that the BART to SFO project was not subjected to required cost effectiveness examinations, because the roll up brought the federal cost share of the combination of four projects below the threshold of 33%. At the time, RAFT wrote to the OIG on this troublesome issue. One interesting factor is that one of the three other fixed guideway projects was already in revenue service at the time the EIS was finalized.

Ridership is much less than expected and the service on the extension will be cut in half soon, according to a press report.

A Mega Project that has Received FTA Clearance to Advance to Preliminary Engineering
BART to San Jose is expected to cost about $4 billion, and the transit operator sponsoring the project will be seeking a Full Funding Grant Agreement for $834 million. The project was not considered viable until former Governor Davis surprisingly offered to include the project in the state's Transportation Congestion Relief Program and allocate about $700 million towards it. The Legislature has since transferred funds from the TCRP to the General Fund, and our current Governor has indicated that the projects in the TCRP should be canceled.

The principal purpose for the project, as we understand it, is to bring commuters from the area of the Altamont Pass (eastern Alameda County) to San Jose and Santa Clara.

Weighing Viable Alternatives
Several large transit projects to connect southern Alameda County with San Jose have been reviewed by our MPO over the past ten years. Alternatives have included buses, commuter rail and BART.

This mode is the lowest cost and needs the shortest time to implement. There are now new HOV lanes in operation between Fremont in Alameda County and San Jose on I-880. Buses could run in these lanes. Bus alternatives have generally been discarded by policy makers early on in reviews of alternatives for a transit project in the corridor.

Commuter Rail
The transit operator in Santa Clara County was moving forward with a commuter rail alternative until the Transportation Congestion Relief Program was created. This alternative thereafter was stricken from long range plans and the most costly BART technology alternative became the favored alternative.

Costs per new rider, performed by our MPO, for the bus, commuter rail and BART to San Jose alternatives are available on line at http://www.mtc.ca.gov/projects/blueprint/briefing/brief19.htm. The cost for BART is given as $100.30 per new passenger trip.

High Speed Rail
Santa Clara County's transit operator has vigorously rejected the study of an alignment over the Altamont Pass (generally, running next to I-580 between Livermore and the San Joaquin Valley). This is unfortunate, because only with the Altamont alignment can the need raised by the Santa Clara County transit operator for BART be satisfied, but without having to spend $4 billion on BART itself. In short, the Altamont alignment for High Speed Rail is a substitute for BART. It is also significantly faster in terms of travel time and is also less expensive to build. High Speed Rail likely would also have a lower subsidy per passenger trip than would a BART to San Jose passenger trip. Needless to say, RAFT believes it would be useful to know if the Federal Railroad Administration is working closely with the Federal Transit Administration on the continuing review of BART to San Jose.

Our MPO's Regional Transportation Plan is supposed to be "fiscally constrained." Unfortunately, it appears that the addition of the BART to San Jose project in it "unconstrained" the plan. It is likely that what happened is that the sponsor forgot to include the financing costs of constructing the project in the total cost of the project when the RTP was adopted by the MPO. The financing costs are now recognized as substantial, at least $800 million.

Quantitative Measures
The high cost per new passenger of $100.30 for the BART to San Jose project is more than enough to give every new passenger an imported luxury sedan every three years, forever.

Very shortly before the RTP was adopted, the cost per new passenger had been reduced significantly to a range around $22.50. It appears that an adjustment was not made on the cost side of the equation, but on the estimated number of new passenger trips. By assuming a tremendous number of high rise offices in downtown San Jose, the number of estimated new passenger trips was increased by about four times. Your auditors may wish to delve a bit into the forecast of passenger trips on the proposed extension. Where did the new forecast originate, with the officials responsible for the ridership predictions of BART to SFO, or with the Santa Clara County transit operator, which is responsible for the estimate of passenger trips on the Tasman light rail line, its most recently opened fixed guideway transit project? The Tasman EIS from 1992 provides an estimate of about 10,000 passenger trips a day on the line, which is now in revenue service. Measurements of actual ridership earlier this year show ridership is less than 3,000 passenger trips a day.

Operational Issue-Existing Bus Service
The Santa Clara County transit operator has pledged $48 million a year from funds it uses to operate its bus service (about 100,000 passenger trips per day) to subsidize the operation of the BART to San Jose project. There is no secured source of funding for the BART to San Jose project, and RAFT is concerned that bus service would be reduced by a large amount as a result. Your auditors may want to determine if existing transit service that will be cut saves more or less than the cost of providing the new BART to San Jose service.

There are many documents available on both of these megaprojects. If your auditors are unable to locate documents they need in their work from the files of the FTA or of the transit operators/project sponsors/grantees, we may be able to provide them.

RAFT is available to discuss the two projects if that would be helpful to your auditors. Lastly, RAFT is a transit advocacy organization.


M. Kiesling for RAFT

Representative Istook
Senator Shelby