The Sounder North commuter rail service between Seattle and Everett is proposed by Sound Transit to be maintained in its present form in both the 2013 Budget and the 2013 Service Implementation Plan. The following comments are directed to the Sound Transit Board of Directors in connection with the Public Hearing requirement for both documents, held on November 1, 2012. As a Seattle resident and informed citizen of the Sound Transit taxing district, I have been following the development of Sound Transit's mass transit system since the early 1990s. My testimony here is informed by the September 20, 2012 report of the Citizen Oversight Panel (COP) North Shore Alternatives Task Force.
I urgently recommend that the Sounder North service be discontinued and the resources now devoted to operating it be shifted to Regional Express Bus services in the same corridor. The basis for my recommendation is first, that Sounder North costs so much in conjunction with its present and forecast ridership that the train is illegal under state law, and second, that existing express bus service expanded somewhat to reduce headways and reduce crowding can be easily set up to provide a functionally equivalent trip.
According to the COP report, the Sounder North train service costs about $9.1 million per year to serve a range of 1,100 to 1,200 one-way riders per day. The cost per boarding in 2011 as reported by COP was $32.38, not including capital costs. At the same time, a frequent, all-day express bus service from the same agency covers the same corridor and the same intermediate stops with a similar travel time along the I-5 HOV lanes, and a much lower operating cost of about $5.11 per boarding.
In the life of this train since December 2003, the maximum ridership achieved has been 1,200 one-way boardings per day. In the first half of 2012, the ridership averaged 1,013 per day. The forecast made in 1996 for daily ridership in 2010 was 2,400 to 3,200 boardings daily, and it was on the basis of this predicted ridership that the train was established.
To set the legal basis for operating commuter rail in Washington State, the Legislature and Governor in 1990 established a legal framework codified as RCW 81.104.120. This law states, "Transit agencies and regional transit authorities may operate or contract for commuter rail service where it is deemed to be a reasonable alternative transit mode. A reasonable alternative is one whose passenger costs per mile, including costs of trackage, equipment, maintenance, operations, and administration are equal to or less than comparable bus, entrained bus, trolley, or personal rapid transit systems."
In simple terms, the law states that the train must be less expensive than using buses.
The minimum current passenger cost per mile can be approximated as the $32.38 cost per passenger boarding noted above divided by the 35 mile route length, that is, 93 cents per passenger mile. This would come out higher if we took into account that many passengers board/exit at Edmonds or Mukilteo and thus travel less than 35 miles, certainly raising the per passenger mile cost to over a dollar. It also would come out much higher if capital costs were included. However, let's assume 93 cents, because this train costs way too much even at this level.
The determination that the RCW 81.104.120 law requires is whether 93 cents per passenger mile is equal or less than riding a bus on the same route. We can show that the train cost is much higher than the bus cost.
In the 2013 Draft Service Implementation Plan, Sound Transit has reported the cost per boarding of its Regional Express Route 510 bus between Everett Station and downtown Seattle as $5.11 on weekdays. When divided by the same 35 route miles, the cost per passenger mile calculates to 15 cents per passenger mile, or 84% less than the Sounder train.
While our analysis makes an assumption that all the train passengers travel between Everett and Seattle, more detailed data would show a similar result if the Edmonds and Mukilteo customers were considered separately. These cities are also served by bus service to downtown Seattle that can be adjusted to be functionally equivalent to train service by using a small amount of redirected Sounder North funds after this train is stopped.
The historical record of the implementation of 1994 Resolution 24 (attached) of the Regional Transit Authority indicates that Sounder North train was expected before service began to operate at a passenger mile cost of 33 to 38 cents, which even incorporated capital costs. This was based on a plan to attract 4,600 boardings per day. Bus costs were stated as 40 cents per passenger mile, with no methodology stated on how this cost was calculated, but undoubtedly including capital costs. Because 38 cents is less than 40 cents, the Sounder North Line train in the 1990s passed the reasonableness test of RCW 81.104.120.
Now, operating experience can replace theory. Sound Transit reports that the Sounder North costs are higher than planned in 1996, and the ridership lower.
After a decade of operation since 2003 during which Sound Transit marketing programs have had plenty of time to attract more ridership, the passenger mile cost of the train is not equal or less than the bus, but much more. The train is more than 93 cents per passenger mile, and the bus is 15 cents.
Lately Sound Transit has proposed leasing about 103 additional parking spaces in Edmonds to attract more riders into boarding at that intermediate point on the line. However, this will raise costs for a small increment in ridership, so small that the increment will not change the calculation of cost per passenger mile significantly and the Sounder North service will continue to be illegal.
Because of the cost figures derived from operating experience, I assert that the Sounder North Line train can no longer be considered a reasonable alternative transit mode under RCW 81.104.120. Sound Transit should declare this train to be illegal and discontinue it. Resources no longer needed to operate it should be committed to strengthening Regional Express bus service in the corridor between Everett and Seattle, which the COP has reported to be so well-used that passenger have to stand in the aisle.
If my recommendation is not implemented, I have an alternative request that explanatory information be provided to citizen taxpayers: The Sound Transit Board should explain in writing why RCW 81.104.120 was applied in 1994 with calculations shown as though this detail mattered, and why now in 2012 the law is being ignored.
Additional Background
Concerned about low ridership, the Sound Transit Citizen Oversight Panel (COP) has conducted a study of the Sounder North Line, which began with a formal presentation of cost and ridership data to COP by Sounder management on March 1, 2012. Excerpted data from that briefing are posted here (pdf).
On September 27, 2012 the COP issued a report on its study results to the Sound Transit Board of Directors, with a summary cover letter, here in pdf. The report states, "We do believe that the Board and the public should be aware of just how costly this service is and what the implications are of continuing to allocate scarce resources to an underutilized service when the alternative express bus service is running overcrowded every day with standees in the aisles, at a much lower cost."
The Power Point slides used by
COP for the briefing to the Board are
available here in PDF.
The COP study concludes "the status quo of low ridership and high costs on North
Sounder is not acceptable." The report advocates the agency take steps to
increase ridership, but does not recommend shutting down the service even if
ridership remains low, alleging that the existence of this costly, poorly
patronized train is supported by leaders and many other citizens in Snohomish
County.
The COP report makes no mention of Washington State law RCW 81.104.120 described below, which PITF asserts establishes a justification for shutting down Sounder North.
Response from Sound Transit
reported by
Matt Rosenberg in Public Data Ferret: "Sound Transit spokesperson
Kimberly Reason said the board will have a formal response to the [COP] report
[about Sounder North] in 30 days. She emphasized the agency has made a
considerable investment in commuter rail to Snohomish County including more than
$200 million to BNSF for an easement to use the freight line’s tracks; and that
voter-approved plans also bind the agency to continuing North Sounder service.
She did say that to improve North Sounder ridership, ST is exploring leasing
space for surface parking near the Mukilteo and Edmonds stations, considering
improvements to bike and pedestrian access, and continuing research and
marketing efforts. Adding to ST Snohomish County-Seattle express bus service is
a non-starter, she said, because the agency is at peak hour capacity in that
respect, and because adding new coaches would require unfunded spending for the
rolling stock, plus maintenance. Reason also asserted that in the long term,
Puget Sound regional roads will become less and less viable due to congestion
and that train transit (commuter rail and light rail) will become a better and
better option compared to buses or cars."
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Last modified: December 25, 2012