RailPAC submits comment letter to Connect SoCal 2024 regional transportation plan


Draft Connect SoCal Plan Comments
Attn: Connect SoCal Team
Southern California Association of Governments
900 Wilshire Blvd., Ste. 1700
Los Angeles, CA 90017

[to be submitted via online form]

January 11, 2024

Re: Public comment on Draft Connect SoCal 2024

Dear Connect SoCal,

The Rail Passenger Association of California and Nevada (RailPAC) is an all-volunteer non-profit passenger rail advocacy group representing the interests of rail passengers since 1978.

RailPAC appreciates this opportunity to provide public comment on the Draft Connect SoCal 2024 Southern California’s Regional Transportation Plan/Sustainable Communities Strategy for the six-county region—as required by federal and state regulations. As the nation’s largest federally-recognized metropolitan planning organization, the Southern California Association of Governments (SCAG) is in a unique position to encourage all levels of government to work together to improve passenger rail service and general mobility in Southern California.

Improved regional and intercity passenger rail must be a cornerstone of Southern California’s transportation and land use investments between now and the year 2050. RailPAC sees improved regional and intercity passenger rail as critical, along with complementary improvements in the freight rail system. Aside from the obvious environmental benefits of reducing air pollution and providing additional transportation capacity, efficient passenger rail travel is vital to California’s economic well-being. The livelihood and security of all Californians cannot be dependent upon increasingly congested and deteriorating highways, rail networks and airports. The needs of non-drivers are just as important as those of drivers. Millions of residents in the SCAG region do not drive because they are too young or too old, have a medical condition that prevents them from driving, or cannot afford a car/truck or the fuel needed for all trips. Rail and transit should be viewed in this context.  Representation of ‘non-drivers’ thus needed on boards and other representative bodies governing transportation in the SCAG region.


Brian Yanity
Vice President- South and Board Member,
Rail Passenger Association of California and Nevada (RailPAC)
Fullerton, California
Email: [email protected]

[specific comments on draft Connect SoCal 2024 plan on following pages]

Mobility Technical Report

RailPAC has always focused on intercity passenger service and regional rail. While it is important to move large numbers of people short distances by transit, it is equally beneficial to the community to move smaller numbers of passengers over relatively longer distances.  An intercity train journey of 70 miles or more is the equivalent to a dozen or so local transit journeys in terms of vehicle miles avoided. Investment in Intercity and Regional Rail in the SCAG region has been totally inadequate for decades. Southern California is also behind in the fight against air pollution, including greenhouse gas emissions- as transportation emissions rise while those of other sectors decline. Regionwide rail electrification is long overdue.   

The Mobility Technical Report’s vision for transit/rail (Ch. 2) sets a very positive tone for transit and passenger rail in the SCAG region over the next few decades, why it is important (2.10), with goals to grow ridership and provide more frequent, and new, rail services. The report also makes astute observations and recommendations about rail and transit funding (2.14.1) safety and security (2.14.2), the built environment and subsidization of driving (2.14.4), and transit-oriented development (2.17.8)- highlighting the need to mode shift from transit to rail.

RailPAC appreciates the report’s highlighting of the importance of Amtrak Pacific Surfliner, connecting Amtrak Thruway buses, along with Amtrak’s long-distance National Network trains: the Coast Starlight, Southwest Chief and Sunset Limited (p.45-46). In addition to connecting the SCAG region to the rest of the nation, the Amtrak long distance trains also provide a valuable transportation service within the region, as this section mentions- the only available passenger rail service to Palm Springs (Sunset Limited), as well as Victorville, Barstow and Needles (Southwest Chief).

It is anticipated the FRA’s Daily Long-Distance Service Study[1]will recommend additional intercity passenger rail service between Salt Lake City and Los Angeles and a daily Sunset Limited (up from the current three days per week). In addition, future FRA Corridor ID initiatives may see recommendations for additional intercity passenger rail service between Tucson/Phoenix and Los Angeles. The expansion of on-dock loading of containers at the Ports of Los Angeles/Long Beach coupled with the establishment of inland ports in Las Vegas, Salt Lake City and Phoenix/Tucson should result in expanded container trains on UP’s two key transcontinental routes, Los Angeles – Las Vegas/Salt Lake City and Los Angeles – Phoenix/Tucson. As a result of these initiatives additional rail line capacity will be needed, likely a 2nd main track on Cima Hill on the line to Las Vegas – Salt Lake City, and completing the 2nd main track between Coachella, CA and Yuma, AZ on the Yuma Subdivision of the Sunset Route. Additional capacity projects such as these will provide on-time performance benefits to Amtrak trains. Reliability and frequency of long-distance interstate Amtrak trains should be counted as another benefit of SCAG region capacity upgrades to the BNSF and UP mainlines on which they run.

RailPAC also supports restoration of the Coast Daylight, and appreciates SCAG acknowledging the planning efforts underway to run a new direct train between Los Angeles Union Station and San Francisco’s new Transbay Terminal (under Coast Starlight, p. 45-46) on the existing Coast Route. SCAG should work with the Coast Rail Coordinating Council and San Luis Obispo Council of Governments to make a new Coast Daylight a reality.

Remote/telework/hybrid work (p. 69-70):

Remote and flexible work arrangements reinforce the need for more round-the-clock regional rail services by Metrolink and Amtrak, as trips between home and the office are less likely to be traditional morning and evening commuting times. Note that this trend often results in longer trips as remote work enables individuals to live further from the core office or in the case of independent contractors work part time for two companies, one in city A the other in city B, in the opposite direction.

Climate change (2.14.3, p. 70-71) and the San Clemente inland bypass:

An inland, double-tracked and electrified bypass is needed for the LOSSAN Rail Corridor to avoid the near sea level alignment through San Clemente, a serious capacity constraint on the key route between California’s two largest cities, and at increasing risk to climate change-driven coastal erosion and landslides. Most likely a tunnel underneath I-5, Caltrans, OCTA, LOSSAN Rail Corridor Agency and other agencies should start doing geotechnical, environmental and design studies on tunnel options through San Clemente, Dana Point and San Juan Capistrano.  SCAG can help facilitate this process. Regardless of the resiliency risks to this vital piece of infrastructure, we still are trying to operate a modern service with many miles of single-track railroad between the 2nd and 8th largest cities in the United States. The LOSSAN corridor needs to be double-tracked and electrified the whole way between LA and San Diego.

Agency coordination (2.14.5 p. 72-73), regional rail governance and the role of the state:

The state government (CalSTA, Caltrans, CHSRA) needs to take a more leading role in governing regional rail in Southern California, especially on the LOSSAN Rail Corridor. County transportation agencies do not have the scope, capability and capacity to cohesively manage and improve the entire 351-mile corridor to its full potential. This is especially true in the case of the LOSSAN’s needed megaprojects such as Link Union Station, San Clemente and Del Mar tunnels.  One issue is that county transportation agencies tend to be hyper-sensitive to local neighborhoods often to the detriment of projects with regional benefits. On January 9, 2024, the California Senate Transportation Subcommittee on LOSSAN Rail Corridor Resiliency sent a letter to CalSTA “calling on the state to take a stronger role in managing the line and the many agencies involved with it”[2].  RailPAC, Streets for All and other organizations have written a joint letter echoing this sentiment and calling for a state-led reform of regional rail governance, to be submitted to SCAG separately.

Regional projects (2.16.1, p. 80-82):

California High Speed Rail, with its transformative plans to connect the Antelope Valley, Burbank, Los Angeles and Orange County with tremendous mutual benefits for LOSSAN and the Metrolink system, needs to be discussed in this section.

Link Union Station-

The railroad tracks approaching Los Angeles Union Station, the hub of the regional passenger rail network, are circuitous and serpentine, unnecessarily adding 5 to 10 minutes to every journey. 

The existing inefficient stub-end track configuration needs to be upgraded to a run-through layout, to avoid every train having to reverse in the station. Run-through tracks significantly increase the number of trains that can serve the station. The run-through tracks should have been completed with the original plan when Union Station was built in the 1930s, but here we are nearly a century later. It is past time to start building. The Link Union Station project, while briefly mentioned under ‘rail capacity constraints’ (2.14.8, p. 75), needs to be discussed in further detail as a critical regional project. SCAG should be working with LA Metro, California High Speed Rail Authority (CHSRA), SCRRA[Metrolink], and other public agencies in expediting its final design and construction.

p. 82:

San Bernardino County-

The statement, “in the near future, SBCTA will introduce its electrical multiple units (EMUs) on the Arrow service, using zero emission fuel cell propulsion”, is inaccurate. The Stadler multiple-unit train will not run on electricity, but hydrogen (the exact source of which has not been publicly disclosed).  

Riverside County-

Extension of the Coachella Valley Rail to Calexico in Imperial County should also be studied.

2.17.1 System preservation and resilience:

Rail electrification (also discussed on p. 64-65 of the Clean Technology Compendium report)-

The brief discussion on zero-emissions rail (p. 85-86) acknowledges that overhead catenary rail electrification is ”relatively mature and have been deployed elsewhere – particularly outside of North America, such as many European and Asian countries”, yet neglects to mention how the plan for CHSRA to install 25 kV overhead catenary wire between Burbank, LA Union Station and Anaheim, could also be utilized by Metrolink and Amtrak trains sharing the same tracks. The Brightline West line between Rancho Cucamonga and Las Vegas will also be powered by 25 kV catenary on its new, dedicated tracks. Also slated to begin construction soon is 25 kV catenary on the initial operating segment of the CHSR project in the Central Valley. The new Caltrain electric Stadler trainsets will start carrying passengers in 2024 under 25 kV catenary wire between San Francisco and San Jose. California is thus emerging as a hub of 25 kV overhead catenary development in the United States, and the SCAG region stands to benefit from this ‘local know how’.

The superior performance, energy efficiency and reliability of conventional rail electrification has been proven for all types of rail operations around the world, with many different vendors and suppliers of the technology. The SCAG region’s core rail mainlines should be electrified with 25 kV overhead catenary, the world standard. Around the world, there has long been a well-documented increase in passenger train ridership following electrification, nicknamed the “sparks effect”. This is because electric trains have:

  • Increased train speed and frequency due to better acceleration
  • Passenger comfort (quieter, smoother ride, no smoke)
  • Increased reliability (fewer train breakdowns)
  • Lower equipment, operation and maintenance (O&M) costs means passenger railroads can invest more in frequent service.

Hydrogen rail propulsion is unproven, has very poor overall energy efficiency (less than 40%, compared to over 90% for conventional overhead catenary electric trains), is inherently more complex (with more potential points of failure) with higher O&M costs. One critical issue for regional planning of electric transportation is the overall electric energy consumption of transportation. Because rail transportation is on average three times more energy efficient than road transportation, it takes one third of the electric energy consumption to move the same amount of passengers/freight with an electric train, compared to an electric truck or bus. Electric trains per passenger are even more energy efficient compared to electric cars. SCAG should be encouraging electric rail, in its most efficient form with overhead catenary, to make the most of energy available on the electric power grid.

The emissions comparisons of rail technologies (Tables 20, 21 and Figure 18 on p. 64-65 of the Clean Technology Compendium report) only show battery and hydrogen fuel cell technology, and not conventional rail electrification. This is a glaring omission. Electric trains using overhead catenary need to be compared as a technology option and on a lifecycle cost/total-cost-of-ownership basis, along with overall energy efficiency shown for each technology type.

The first hydrogen trains introduced in Europe cost four times more than their electric equivalents, and have been plagued with reliability problems and cost overruns. The price of hydrogen is also volatile as over 95% of it produced in the world comes from natural gas- a commodity highly vulnerable to market price swings and geopolitical risks. Green hydrogen- made from renewable electricity- is several times more expensive than dirty hydrogen from fossil fuels- and requires large amounts of freshwater for its production. This will be a challenge in dry regions such as Southern California. International experts, informed by the actual performance of different zero emissions rail technologies in revenue service in Europe and elsewhere, are coming to consensus that improved battery and hydrogen technology will not replace the need for overhead wire electrification on the busiest rail lines. As concluded by a 2021 report by the UK Railway Industry Association[3]:

“Evidence does not support the view that [overhead wire rail] electrification is unnecessary, thanks to hydrogen and battery systems improving rapidly: hydrogen trains are inherently less efficient than electric trains, due to the physical properties of the gas. Expert opinion predicts that battery capability might double by 2035. Yet, whilst this might affect the hydrogen / battery traction mix required for decarbonisation, it is unlikely to change significantly the requirement for electrification.

The laws of nature make electrification a future-proofed technology that is a good investment, offering large passenger, freight, and operational benefits. Furthermore, railways cannot achieve net-zero carbon emissions without a large-scale electrification programme.”

In a 2020 analysis of technical abilities of non-diesel rail traction technologies, from “Traction Decarbonization Network Strategy – Interim Programme Business Case –Executive Summary”[4] report by UK Network Rail, electric with overhead catenary was the only zero-emissions propulsion mode viable for all speeds of passenger and freight service. Hydrogen was only determined to be ‘good’ for passenger trains under 75 mph, fair for 100-125 mph, and poor for freight and passenger over 125 mph. Battery was judged to be ‘fair’ at best for passenger trains up to 100 mph, and poor for all other applications except certain freight (yard switching and short distances). The report concluded that, for the currently unelectrified lines in the UK, rail decarbonization requires overhead catenary electric, hydrogen and battery traction operating on respectively 86%, 9% and 5% of the rail network.

It should be mentioned here that BNSF Railway has agreed to CHSRA’s plan for 25 kV overhead catenary wire above two of its tracks between LA and Fullerton- tall enough to allow double-stack container trains to pass through on tracks shared with electric passenger trains. That a Class I railroad has agreed to electrification on its tracks is a hugely significant development, with national significance. The Connect SoCal 2024 documents should mention this historic milestone, happening in the SCAG region. SCAG did a study in 2012 on regional freight rail electrification[5], and a regional freight rail electrification plan should be discussed in the Goods Movement Technical Report sections on zero emissions vehicles (4.4.1 p. 76-7), freight rail service (5.6, p. 112) and community and environmental impacts (5.7, p. 112-115).

Project List

There is not space here for commentary on individual projects, given the size of the list.  However, here are some general observations:

  • Connect SoCal’s stated goals of reducing emissions, environmental justice, ‘fix-it-first’ infrastructure funding, increased mode shift from road to transit/rail, etc. are compromised by the fact that there are so many road and highway expansion projects listed. The ‘project pipeline’ needs to be carefully reevaluated, with SCAG pushing back on county transportation authorities’ excessive highway expansion plans, by more scrutiny of proposed and road projects, and directly offering alternatives.
  • In addition to the San Clemente inland bypass described above, vital rail projects that are missing from the project lists include:
    • Serra Siding Extension (north and south, including 2nd San Juan Creek bridge)
    • Raymer-Bernson double tracking in the San Fernando Valley
    • Irvine-Laguna Niguel 3rd mainline
    • San Bernardino Line full double-tracking (including I-10 segment)
    • Completion Fullerton-Riverside-San Bernardino 3rd and 4th mainline track
    • Completion of 2nd mainline track on UPRR Los Angeles and Alhambra Subs
    • Completion of Coachella-Yuma 2nd mainline track (UPRR Sunset Route)
    • Completion of Cima Hill 2nd mainline track (UPRR Cima Sub. to Las Vegas)
    • Simi Valley-Moorpark-Camarillo 2nd mainline track
    • Comprehensive regional (overhead catenary) rail electrification, for both passenger and freight

  • It is commendable that many of rail-road grade separations are counted as ‘local highway’ projects in the project lists as opposed to ‘passenger rail’. Grade separations should be chiefly funded from road and highway budgets, so as to not draw funds away from other rail and transit projects.

  • One project listed under passenger rail (p. 483), “California/Nevada Super Speed Train System” Anaheim-Las Vegas “California/Nevada Super Speed Train Commission”, needs to be deleted- this particular proposal has not made any progress, has no environmental document and has been replaced by Brightline West, which is about to begin construction.

[1] https://fralongdistancerailstudy.org/

[2] https://twitter.com/SenBlakespear/status/1744895809928544468


[4] https://www.networkrail.co.uk/wp-content/uploads/2020/09/Traction-Decarbonisation-Network-Strategy-Interim-Programme-Business-Case.pdf

[5] https://scag.ca.gov/sites/main/files/file-attachments/crgmsais_-_analysis_of_freight_rail_electrification_in_the_scag_region.pdf?1605991886