Hon. Lesa Heebner, Chair
San Diego Association of Governments (SANDAG)
ATTN: LOSSAN Comments
1011 Union St., Suite 400
San Diego, CA 92101
via email to: lossancomments@sandag.org
June 24, 2025
Subject: SDLRR Project NOP, Comments on LOSSAN Corridor Del Mar Rail Realignment Alternatives Analysis
Dear Chair Heebner and Board Members,
I am writing on behalf of the members of the Rail Passenger Association of California and Nevada (RailPAC) living, working, and traveling along the LOSSAN Corridor. RailPAC is an all-volunteer 501(c)(3) statewide organization that advocates for the improvement of commuter and intercity passenger rail service.
RailPAC strongly supports the goal of transforming the LOSSAN Corridor into a high-performance, high-capacity auto competitive rail corridor. Moving this vital raillineoff of the crumbling Del Mar bluffs into a protected tunnel alignment is a key step toward achieving this goal. By undertaking this project, SANDAG will ensure that the nation’s 2nd busiest intercity passenger rail corridor will continue to serve many generations in the future, creating tremendous value for Southern California residents while reducing GHG emissions and avoiding ever widening freeways.
RailPAC strongly supports the alternative alignment under Camino Del Mar. This option under Camino Del Mar, transitioning to the existing right-of-way through Los Penasquitos Lagoon, is the shortest, and lowest-cost tunnel option. The deep tunnels (100-200 feet) directly under the two streets would cause no more disruption during construction and operations than a deep subway tunnel under a street as has been done in many major cities worldwide, including in California. The lagoon segment will be raised and double-tracked and include improvements to improve lagoon habitat with additional bridges to improve water flow, address flooding and sea level rise. The track speed rating should be 90-mph.
RailPAC strongly opposes the “No Build” and “Del Mar Bluffs Double Track Reinforced (in existing right-of-way)” alternative alignments, because the rail line needs to be rerouted off the eroding bluffs. The “San Dieguito Bridge to I-5” alternative alignment should also be rejected. It is the most expensive tunnel option, yields no train run time savings and will be and risky operational challenge for freight trains.
The Camino Del Mar alignment lends itself into being split into two distinct construction segments, the tunnel segment and the lagoon segment. This could aid in construction sequencing and utilization of the flow of funds. In addition, if the lagoon segment, a less complex segment, is constructed while the tunnel design is underway, the second track could be used to support tunnel construction delivering by rail construction materials and the haulage of tunnel spoils by rail.
RailPAC urges SANDAG to futureproof the tunnel by building it with enough vertical clearance to accommodate both an overhead contact system for rail electrification, and the tall auto-rack cars that serve the Port of San Diego. Electrification is the global gold standard and is well proven for successful frequent and fast passenger trains around the world. It is crucially important for enabling higher train speeds and frequencies and will be more than economically justified by the train frequencies of up to four trains per hour envisioned by long-term plans for the corridor. Finally, hydrogen train propulsion in the confined space of a tunnel has tremendous safety risk due to hydrogen leakage.
The San Diego/Del Mar LOSSAN Rail Realignment Project is critical to the surrounding communities and the region. As SANDAG makes the routing strategy, the needs of the region’s twenty-two million people for improved mobility and reduced greenhouse gases from transportation need to be the foremost consideration.
Thank you for your consideration.
Sincerely,
Brian Yanity
Vice President- South and Board Member, RailPAC
Fullerton, California