July 31 2002

Department of Transportation
Office of Inspector General
400 Seventh Street, S.W.
Washington, DC 20590

by email: hotline@oig.dot.gov

Re: San Francisco Bay Area-Financial Capacity Policy

Dear Inspector General:

The San Francisco Bay Area Rapid Transit District ("BART") has invested millions of dollars in federal funds (e.g., CMAQ funds) to finance a project called "Advanced Automatic Train Control ("AATC")." According to BART, the purpose of the project is to "enable the BART system to nearly double its train carrying capacity. When implemented between Bay Fair and Daly City stations, this project will allow system throughput to increase from the current 21 trains per hour up to 30 trains per hour." BART Capital Improvement Program Fiscal Years 2001-2010, p 2-24. http://www.bart.gov/about/reports/srtp.asp

Due to its significant financial problems, BART is going to cut service, not increase it. A Letter to the Editor from Ron Rodriguez, a BART official states, "We will lower our daily weekday train trips from 700 to 687." Letters to the Editor, San Francisco Chronicle, Monday, July 15, 2002. http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2002/07/15/ED208377.DTL

The funds invested in the AATC project cannot be recovered, as the project was declared operative last month.

How does cutting transit service support the federal investment in this $100 million expansion project, in light of the Federal Transit Administration's "Financial Capacity Policy," as set out in FTA Circular C7008.1 E, dated 03-30-87?

Another BART capital project that has utilized both Surface Transportation Program and §5309 funds through the MPO is known as the "A/B Car Rehabilitation Project." The Inspector General issued an Audit Report on October 31 1995 entitled "Useful Life of Rail Cars Bay Area Rapid Transit District." One of the findings was that BART has too many cars, tying up several hundred million dollars of federal funds that could have been invested elsewhere. The funds invested to rehabilitate the unnecessary cars cannot be recovered, as the project will be finished within a few months.

How does cutting transit service support the federal investment in this $400 million project, in light of the FTA Circular C7008.1 E 03-30-87?

Is FTA reviewing BART's financial capacity to determine if there are other fixed guideway expansion projects that are utilizing federal funds while BART cuts its service? BART is currently designing extensions in detail to San Jose (along with Santa Clara Valley Transportation Authority, which is cutting service on dozens of its bus lines; see http://www.vta.org/news/2002_proposed_revised.html) and to the Oakland Airport, and is in early planning stages for providing fixed guideway transit service on three additional lines. How does cutting existing service support 49 U.S.C. §5309(e)(4)(C)(iii) with these proposed fixed guideway projects?

Furthermore, BART and samTrans (which is cutting its bus service significantly in order to help fund the rail extension) are now constructing a fixed guideway project to San Francisco Airport. This project has a Full Funding Grant Agreement, and the recommendation is for the project to receive $100 million in federal funds for FY 2002-2003. How can both operators cut existing service, in the midst of construction of a fixed guideway mega project, in light of 49 U.S.C. §5309(e)(4)(C)(iii)?

RAFT appreciates your clarification of these issues

Sincerely,

For RAFT

M. Kiesling