RailPAC submits comment letter to joint hearing of California Senate and Assembly Transportation Committees on transit ridership

Assembly Transportation Committee
Legislative Office Building
1020 N Street, Room 112
Sacramento, CA 95814

Feb. 27, 2023

Re: Joint Informational Hearing, Short-Term Crisis and Long-Term
Transformation of Transit in California

Dear Chair Friedman and Chair Gonzales and Members,

On behalf of the all-volunteer Rail Passenger Association of California and Nevada
(RailPAC), I want thank you for your initiative in highlighting and developing strategies to address this critical issue.

RailPAC’s comments will focus on commuter rail (Caltrain, Metrolink, etc.) since these are services with higher pre-pandemic revenue/cost ratios and thus have seen the greatest shortfalls in revenue. Also with a high percentage traditional of 9-5 office workers, their historic core market has seen the greatest transition to work-from-home and the hybrid workplace with little indication that, except marginally, this ridership will even return. Thus compared to urban transit these commuter rail lines and the invested public capital they represent are in need of radical transformation.

Compared to the “rush hour” focus of commuter rail, regional rail offers uniform service throughout the day and on weekends with late-night service for workers with non-traditional work hours. And discontinuance is not an option. The transportation corridors these carriers operate in cannot forgo the transportation capacity they represent. Also as noted in the Background Paper, robust ridership growth of this low-carbon mode is critically needed to meet the state’s goal of carbon neutrality by 2045.

RailPAC shares the Committee’s concern about future funding sources, especially for the State Transit Assistance (STA). There is also risk in the transition to a VMT payment structure, and any congestion pricing initiatives are stalled. Historically, given the level of revenue generated by users, commuter rail lines have had less concern about meeting revenue/cost goals although this could be of concern until ridership is rebuilt. However, it is critical that funding sufficient to maintain current services and ridership base be identified.

RailPAC is supportive of the focus on the recommendations for restructuring transit funding as outlined by UC ITS. There are two additional actions that RailPAC feels should be explored, especially as part of the transition from commuter rail to regional rail. The first is identifying keystone investments that will speed the transition to regional rail enabling the development of new markets and incremental ridership. The second is improving ticket revenues by generating incremental riders combined with targeted measures to increase selected ticket yields. This opportunity, driven by new fare technology, is more fully discussed in the fare section. One of the key metrics of the transition to regional rail will be a strong growth in ticket revenues

Safety and Security
Addressing safety and security issues is one of the most important factors in transitioning the product and building regional rail ridership. For regional rail riders this is generally a first-mile/last-mile issue, the connecting urban transit trip, walking and cycling on urban streets and the walk through a station parking lot. All indications point to any rider with a choice is choosing the auto even as traffic congestion grows. Safety and security is also a barrier to capturing non-traditional work trips outside the 9 to 5 model and leisure trips. Finally, those most at risk until this issue is resolved are transit dependents – the elderly, disabled, youth and lower income essential workers.

The underlying factors driving this issue also impact regional rail service quality and reliability which negatively impacts potential ridership growth. The camps along rail lines are a source of trespasser incidents leading to long delays and schedule cancellations.

Service Integration
Creating a high quality, high frequency and seamless public transportation network offering service when customers need to travel is the key to driving ridership growth. Yet too often the customer faces uncoordinated connecting schedules or no connections, multiple fare purchases, physical gaps between systems, informational barriers, etc. There are many causes for these shortcomings. Some are due to capital funding short- falls, others due to “stove-pipe” thinking within agencies, fear of revenue loss if there are through fares or pooled service, etc. Most frustrating for RailPAC members, are service integration gaps due to agency or intercounty “turf battles”.

For regional rail, RailPAC feels the county level governance structure hinders viewing the service as a whole; focus tends to be just on intra-county service. Other alternative governance structures should be explored – the multi-county owned but independent terminal railroad model is one example.

Ticket Revenue/Pricing
As was noted in the background paper “user preferences are more impacted by the quality of the public transport service than its price”. A highly discounted fare for mediocre or canceled service that forces a rider to take a high priced ride-share several days a week is no bargain. A higher fare for quality service may in fact be less expensive than the current situation, even for the working poor.

In short as commuter rail transitions to regional rail and the issues noted above are addressed and strategies mentioned in the background paper are implemented, revenue gains can come, not just from a ridership increase, but from increases in ticket yield.

Aiding in this will be new fare/ticketing policies and technology that facilitate Customer Relationships Marketing. The California Integrated Travel Project (Cal-ITP), which facilitates fare capping, replacing a multi-ride discount fare with its high up-front cost and rigid city pair limits, will allow expanded opportunities to create fare levels that match customer needs and income while incentivizing additional trips. This enhanced customer relationship also offers the opportunities for expanded partnerships with station area businesses expanding customer value further.

The “Weaponization” of Environmental Laws
Just as has been seen with housing, environmental laws have been used to stop critical transportation investments. In many cases these investments are critical to the transition from commuter rail to regional rail. Most agencies have projects that have been abandoned, stalled or are moving at a glacial pace as a result of this opposition. The result of this “weaponization” is to turn regional transportation policymaking over to a specific group of stakeholders. The operation of more trains, reducing Greenhouse Gas Emissions thru electrification, should not be a violation of an environmental law.

As in housing, there could be legislation allowing categorical exemption for projects on an existing rail line within the right-of-way. Or, to address the immediate fiscal crisis, specific projects that are turn key for the transition to regional rail could be exempted.

Unfunded Mandates
Currently commuter rail carriers are subject to some unfunded mandates designed to meet overall societal goals. One example is the forced early retirement of recently purchased Tier 4 locomotives fueled by recycled fats and vegetable oils (a low-cost reliable low- carbon transition strategy). Given the fiscal crisis and the role expanded regional rail has in shifting riders from high-carbon ICE autos to rail, a review of these mandates is warranted. This is to make sure that limited agency funds needed for the transition to regional rail are not spent on worthy but less productive goals i.e. “Perfect is the Enemy of the Good”.

RailPAC is an all-volunteer statewide organization that advocates for the improvement of commuter and intercity passenger rail service. Members of Rail Passenger Association of California and Nevada (RailPAC) live, work, commute and travel in the Bay Area, San Joaquin Valley and Southern California. RailPAC is a strong advocate for an expanded, integrated, high-quality public transportation network throughout California. Once again, thank you for the opportunity to comment on this important issue.

Steve Roberts
President Rail Passenger Association of California and Nevada