Letter from PITF to Federal Railroad Administrator about disclosure of grade-crossing cumulative impact in the Environmental Assessment of the Point Defiance Bypass


November 8, 2012

Honorable Joseph Szabo
Federal Railroad Administrator
U.S. Department of Transportation
Washington, DC

Dear Administrator Szabo:

In re: Point Defiance Bypass Project, Washington State, comment period ending November 9, 2012

I am a 30 year resident of Washington State with a deep interest in transportation cost-effectiveness and safety. My profession is public policy and program analysis, which I now practice independently and as an associate of several non-profit organizations.

This letter is a communication from the Public Interest Transportation Forum, a civic information web site I have been operating since 1996 at http://www.bettertransport.info/.  Please make this letter part of the environmental record for the Point Defiance Bypass Project, a track revision which sets up Amtrak passenger trains between Seattle and Portland to move through Lakewood, Washington (just south of Tacoma) on a new high-speed passenger rail corridor at 79 mph, instead of where routed now along the Puget Sound shoreline. There will be 20 at-grade crossing in the urban area where the track passes, already used by slower commuter trains.

In this communication, I'm shining a light on a particular lack of full disclosure of environmental impacts of these 20 road crossings in the Environmental Analysis (EA) for the Point Defiance Bypass Project.

This project was brought to my attention by a journalist’s account published at the online news site Crosscut, April 20, 2011, "Blowing the whistle on plans to shift Amtrak's route south of Tacoma" available for reading at http://crosscut.com/2011/04/20/transportation/20728/Blowing-whistle-on-plans-shift-Amtraks-route-south/. I also noticed the editorial in the Tacoma News Tribune on August 20, 2012, “‘We Can't Wait' for rail bypass? Job 1 is to make it safe” posted at http://www.thenewstribune.com/2012/08/24/2266511/we-cant-wait-for-rail-bypass-job.html.

Based on my examination of an unpublished government working document, a spreadsheet that backs up the grade crossing safety analysis Environmental Analysis, I found that the new passenger rail corridor set up by this project has been professionally analyzed to reveal that the Point Defiance track route is forecast to experience approximately one crash per year at railroad grade crossings along the corridor. However, this quantitative bottom line implication of the analysis is not revealed in the EA.

The Excel spreadsheet I refer to was created by Washington State Department of Transportation (WSDOT) and sent to me after I requested the detailed analytics that were applied to the task of predicting future grade crossing accidents at 20 places where the tracks cross roads.

The spreadsheet calculations of the expected number of annual vehicle-train accidents are used as justification in the EA for an important conclusion: Rebuilding of existing busy rail crossings in City of Lakewood and other jurisdictions to have grade separation of tracks and roadway is not necessary for safe operation.  This conclusion is reached because of the forecast that crashes at any one crossing are forecast to be rare. 

Cumulatively, however, across all of the crossings, the forecast is more troubling – about one crash per year.  There is no apparent statement in the published EA document on this important overall, cumulative effect, or if there is, it’s buried.

The forecast of about one crash per year along all of the grade crossings in this corridor is shown by the number 1.2 years “Between Accidents” in cell Y33 in the Summary worksheet of the referenced spreadsheet provided to me by WSDOT that I have posted to http://www.bettertransport.info/pitf/lakewoodspreadsheet.xlsx .

Significantly, the bottom line “All Crossings” crash forecast numbers produced by WSDOT describe a cumulative effect that is left off "Exhibit 59. Individual Crossing Accident Experience Predicted for Year 2030 Conditions" on page 94 of the Transportation Discipline Report in the Environmental Assessment (EA), a table of numbers copied from the same Summary page of the spreadsheet.   Along with the fact that the raw spreadsheet is not included in the EA as an appendix, the non-reporting of the cumulative effect of high speed trains moving through a set of urban at-grade road crossings is an oversight that should be corrected in the environmental record.

If Amtrak passenger trains are asserted to be safe in crossing busy municipal streets because quantitative analysis implies they are safe, please make sure the U.S. Government discloses fully what the analysis actually shows.






John Niles
Co-founder and Chief Editor
Public Interest Transportation Forum

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