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Rail Passengers Association Submission on Sec. 207 Metrics and Standards

September 5, 2019

Sec. 207 Metrics & Standards

September 2019

On Time Performance

Late trains are the single most significant cause of passenger dissatisfaction. Our members are neither naïve nor intransigent, and recognize that a crucial issue contributing to freight-caused delays of passenger trains is the lack of capacity in the face of growing shipping and passenger traffic, along with a growing strategy within the industry towards so-called “precision railroading.” While sympathetic, the fact remains that our members rely on—and pay for—timely and regular service on those routes.

Many irreplaceable personal moments have been disrupted by these delays, with crucial medical transports affected, weddings and funerals missed and rare home visits by deployed service-members cut short or even cancelled altogether. Each of these hundreds of stories—and we supplied more than 1,300 of them to Surface Transportation Board in October of 2014—add up to more than mere temporary inconvenience and in many cases impose real dollar costs on vulnerable travelers.

Coming at a time of surging ridership, these delays on freight railroads nationwide may well permanently discourage new and first-time riders from exercising their choice to travel by rail.

Rail Passengers urges regulators to measure on-time arrivals at all stations, not just at the end points; to use a single 15-minute standard at each point along a train’s route, and; to trigger an automatic investigation if trains on a route dip below the OTP standard more than 20% of the time.

  • National network trains which can travel more than 2,000 miles between end points.
  • 65% of Amtrak passengers in 24 states get on and off at an intermediate station.
  • Under end point only, some 90% of Amtrak stations’ OTP would never be measured.
  • OTP at route end points is irrelevant to most passengers. Three out of every four passengers using Amtrak’s trains depart from and arrive at stations strung between end point cities, and never set foot in an end point station.
  • The percent of passengers traveling between intermediate points exceeds 50% on three fourths of Amtrak’s 47 routes (see accompanying table with NARP’s route-by-route analysis). Intermediate stations’ ridership is an important statistic throughout the system, and is significant on short, medium and long distance routes.

A random review of the Spring/Fall 2017 timetable shows significant padding on a number of routes prior to end point arrival. This “pad” can be as much as an hour or more. As a result, a train could arrive at the final station on time—and thus meet the new proposed standard—yet have been significantly late at many stations before it and inconvenienced hundreds of passengers on that trip.

Schedule adherence standards should be the same regardless of route length. In the same way that many passengers travel between intermediate points on a route, so too do passengers make trips that are significantly shorter than the route itself. They care about—and have paid for—the train arriving at their destination, not at the end of the route.

Rail Passengers recommends that regulators look more closely at what constitutes an “end point” station, given that there are routes at which intermediate stations constitute end-points for many individual services.

As many routes are currently operated, the very first and very last stations are not always the “end points” on any given frequency. Take as an example the Pacific Surfliner service. Technically, the end points are San Diego and San Luis Obispo. Yet 11 trains a day operate only between San Diego and Los Angeles. Only two serve San Luis Obispo. Santa Barbara has five trains each way per day.

There are similar issues on many other routes, including the Capitol Corridor in California, the Cascades in Washington, New York State’s Empire Service and the Northeast Corridor. Without a clear regulatory definition of where OTP will be measured, a large section of the route network could be completely devoid of any scrutiny and that would be a disservice to the travelling public.

Measuring the Value of Connections

Rail Passengers believes collected and published data should include the effect of degraded OTP on connections, and should require statistical reporting by Amtrak detailing when late trains cause passengers to miss connections or when Amtrak is forced to delay departure of trains for connecting passengers. Collected and published data should also include OTP at key “chokepoints” where passenger trains are handed off from one host railroad to another.

Passengers who use more than one route to complete a trip represent a significant portion of Amtrak’s business. In FY 2015, 2.3 million passengers generating more than $220 million in revenue made connections between trains.

When trains arrive at transfer stations many hours late it can lead to either of two unacceptable outcomes. The connecting train departs late because it waits for the connecting passengers, or the passengers miss the connection and, in cases where there is only one departure a day, arrive at their final destination as much as 24 hours after they had planned.

There are all sorts of consequences from these scenarios. Hotel rooms are cancelled and deposits forfeited, or extra expense is imposed on the traveler. Arrivals that had been scheduled for daylight hours can instead transform into dangerous night-time arrivals at thinly staffed or unstaffed stations; this can be especially troublesome for elderly or disabled travelers, posing a real safety risk which is magnified by these populations’ outsize reliance on trains as their only practical means of long-distance travel.

FRA should be aware of these very real consequences of seriously late trains and consider additional metrics that track not just the percentage of trains that meet the schedule adherence standard but also the amount of delay and how that delay disrupted connections.

Growing congestion in other modes and rapidly dwindling transportation options in small- and mid-sized communities are driving this surge, making train travel more vital than ever to local economies across the nation. As surely as mobility powers economic growth, congestion constrains it.

  • Millions of Americans today face loss of personal mobility: airlines are cutting back the number of flights and have reduced or discontinued service to literally hundreds of smaller cities.
  • Millions more find flying to be too expensive, too inconvenient, or simply too unpleasant.
  • An increasing number of young people don’t own automobiles, either as a personal choice or because they are unaffordable.
  • Many older citizens are unable or unwilling to drive their personal automobiles for more than just a few miles; this population will grow dramatically during the next few decades in the U.S., and their needs must be accounted for.

Rail Passengers recommends that the FRA use its position to lead the effort to create such a framework to address issues that have plagued our national network for decades. As part of this more constructive approach, Rail Passengers believes that FRA could profitably move to set not only a minimum OTP standard, but a target for exceeding minimum standards that could offer greater financial incentives to host railroads that not only deliver superior OTP but reduced trip times and greater frequencies. This could take the form of bonus payments that rise on a scale calibrated to OTP performance, incentivizing private investments in a rail network that can serve not only freight customers but passenger trains at high service levels.

Fully Capturing Value of Service – Economic & Station Development

A study performed by the Rail Passengers and the University of Southern Mississippi discovered that Amtrak’s intercity train service between Albuquerque, NM and Dodge City, KS, was worth $180 million annually to the economies of New Mexico, Colorado.

Using the same economic model, Rail Passengers found that a second Amtrak train between Chicago and Minneapolis/ St. Paul could bring $25 million annually for the state of Minnesota—an economic return of eight- to ten-times Minnesota’s annual net spending to support the potential new service. Our organization found that the overall economic benefit for three states of Minnesota, Wisconsin and Illinois would be $47 million annually—a return on investment of better than seven-to-one.

Rail Passengers believes the FRA should, to the extent possible, determine and publish a broader picture of the economic value of these services, possibly using the rigorous economic-benefits model generated by our association.

Fully Capturing Value of Service - Per Passenger Mile

Amtrak most often utilizes only the “per passenger” metric, which fails to fully capture the public benefits provided by the route. It is important to look at “per passenger mile” cost as well since it states the cost in relation to the length of trip. This helps control for the higher cost of providing transportation services to rural and western U.S. communities. Despite limited service, the 15 long-distance routes account for 42% of passenger miles carried by all of the nation’s intercity passenger trains. Clearly, these routes perform a significant transportation function. As a single instance, by that measure the Chief performs well, falling in the top 50% of all of Amtrak’s routes (23 out of 48).

Rail Passengers believes the “per passenger mile” metric should be included in all route performance analyses to help policy makers and the public ascertain the value of the public service being provided.

Fully Capturing Value of Service – “Overlapping Corridors”

Long distance routes, in effect, represent connected and overlapping corridors. The utility of individual routes grows exponentially when they become part of an integrated system that provides easy transfers to trains on other routes, feeder buses, local transit systems and airports. Such connectivity serves more people, generates greater revenue, drives economies of scale and improves public mobility.

To illustrate the concept, consider the 2,265 mile Southwest Chief corridor between Chicago and Los Angeles. Critics claim that air travel has made such routes obsolete; that it would be cheaper for government to buy each passenger an airline ticket than to run trains on this route. If trains ran non-stop between these two cities, the critics might be right.

Because it makes 31 intermediate stops, it provides a mobility choice for twenty five million Americans who live within just 25 miles of a station (31 million who live within 50 miles) for short, medium and long distance trips between 528 different city pairs with each and every trip.

Data demonstrate that trip lengths vary from very short (as few as 10 to 40 miles) to very long (more than 2,000 miles) and everything in between. Please note that many passengers connect to other trains at Chicago, Kansas City and Los Angeles, so many trips are actually longer.

Long distance routes not only make transportation sense because they serve so many more markets every single trip than air ever could, they also make financial sense. Rail Passengers would like the FRA metrics to fully reflect the number and value of passenger trips dependent upon the intermediate connections on long-distance corridors.

On-Board Service

Rail Passengers understands the constraints under which Amtrak operates – both legal and fiscal – and we want very much to be good partners in fighting for the best passenger-rail service possible. But we have also shared with you in detail our disappointment in the Contemporary product as it was executed on the Lake Shore and Capitol Limited lines. Apart from the introduction of a hot food item we don’t see our concerns reflected in the service as constituted today.

This is why advancing with an expansion of this model is so troubling to our Members: it appears Amtrak is simply barreling ahead with an offering that remains flawed and potentially threatens the attractiveness of the trains without substantively addressing the shortcomings we identified.

Among the issues we have discussed:

  • No purchase option for coach passengers (combined with limited Café Car alternatives)
  • Insufficient quantities and choices loaded aboard the train, with many items unavailable
  • Insufficient hot-food options
  • Insufficient kosher choices
  • Perfunctory breakfast choices
  • Indifferent on-board service and presentation
  • Large quantities of trash waste (the box, the bag, the plasticware, etc.)
  • Presentation and plating

As we have said before, Rail Passengers welcomes the move toward a more flexible dining service, with more choice for passengers—choice about what to eat, where to eat, and when to eat it—but we think the Capitol and Lake Shore experience needs more improvement before going out to more routes. Moreover, coach passengers are completely excluded.

When analyzed in terms of its impact on ticket revenue—not as a stand-alone profit center—food and beverage service on most if not all trains generates more in revenue than it costs to provide. In other words, food & beverage service is incrementally profitable. We believe it satisfies the two requirements that the US DOT Inspector General set forth in its report: that food & beverage service be provided “at no net cost to the taxpayer” and have “a positive effective on net cash flow.”

Understanding Incremental Costs of Service

Rail Passengers strongly believes that the ongoing debate concerning the future shape of Amtrak's national network has been distorted by Amtrak’s overreliance on fully allocated costs rather than avoidable costs, as required by statute.

In our white paper, Rail Passengers explains why fully allocated costing combined with Amtrak’s route accounting system exaggerates the public cost of providing passenger trains as a mobility choice for the entire nation.

For more than 13 years, Congress and other federal agencies have called for more accurate, precise and transparent reporting of Amtrak’s component routes. Numerous arms of government including the Federal Railroad Administration, the USDOT Office of Inspector General (OIG) and the General Accounting Office have all found Amtrak’s route accounting system deficient and not compliant with federal statute requiring disclosure of avoidable costs.

Rail Passengers believes the FRA should work with Amtrak to comply with the current statutes, regulations and Congressional mandates to publicly report the financial performance of each individual route employing the avoidable cost methodology.