Valley to Valley: linking SMART and regional rail

The dream of urbanites across the central Bay Area, as they gaze out towards the golden hills of the Marin Headlands, is BART. They share that dream with the suburbanites who stare back at the picturesque view of San Francisco. That it didn’t happen is now simply a fact of life in the Bay, but we need not live with this fact.

Two weeks ago, I tackled the science of traffic congestion: why it happens and the damage it does to our transportation system [1]. Last week, I examined the best way to cope with congestion – an anti-congestion toll – and how to craft anti-congestion policies with an eye toward equity in Marin [2].

Yet an anti-congestion tolling plan works best when there are effective alternatives. Golden Gate Bus is, when it doesn’t face traffic, a fast and efficient mode of transportation. Unfortunately, it doesn’t run often and it runs into traffic frequently, especially within The City. As well, transfers between it and other long-distance transportation systems like BART and Caltrain are poor at best. Marin and Sonoma residents, then, don’t have viable alternatives to driving if their destination isn’t downtown San Francisco.

The plan in a nutshell

SMART South, as I call this plan to differentiate it from the SMART that is currently under construction, consists of the completion of the SMART system, the upgrades needed to operate at eight trains per hour per direction, and the upgrades, construction, and new trains needed to run SMART south to San Francisco and as a subway under Geary Boulevard.

This will include electrification of the existing line ($125 million [3] for 39 miles of track), pushing SMART north to Healdsburg and south to Marin City ($537 million [i] for 40 miles of surface track), rebuilding the Alto Tunnel ($60 million [4]), tunneling from Marin City to the Golden Gate Bridge ($850 million [ii] for 1.7 miles of tunnel), retrofitting the bridge ($392 million [5]), tunneling from there to the Geary Boulevard Subway ($1,365 million [ii] for 2.7 miles; the Geary Subway segment would be built separately from this project) adding passing track to the existing and new surface line to allow for higher frequency ($705 million [i] for 52 miles), elevating the downtown San Rafael track ($93 million [ii] for 0.6 miles of track), finishing the bike path from Marin City to Cloverdale ($5 million [i]), adding the Corte Madera/Larkspur, Mill Valley, Marin City/Sausalito, Vista Point, and Presidio stations ($500 million [ii]), and buying Caltrain-compatible bi-level electric trains to allow for a much and more frequent longer line ($654 million [6] for 38 3-car trains). There are also $250 million in miscellaneous costs associated with finishing the SMART line as promised. In total, this comes to about $5.5 billion for an effectively-new 85-mile system or about $65 million per mile. That’s quite a steal for American construction costs.

Passengers would be able to transfer at Union Square to BART and Muni’s under-construction Central Subway, and at the Transbay Terminal to Caltrain and high-speed rail. Depending on how the second transbay tube is built, passengers would be able to move on either to downtown Oakland or south to the Oakland Airport and Fremont without transferring.

Funding

The short of it is that anti-congestion charges on the Richmond-San Rafael Bridge (RSRB), Golden Gate Bridge (GGB) and the Novato Narrows could be leveraged into $1.4 billion [iii]. A 0.4% sales tax in Sonoma, Marin, and San Francisco could be leveraged into another $1.3 billion [iv], for a total of $2.7 billion raised locally. Regional, state, and federal monies cover about half the cost of major transit construction projects in California, and that’s the balance of the project. Ongoing operations & maintenance would be covered by fares, tolls, and sales tax income as well as state and federal support. The gritty details of all this, including a speculative financing plan and how to calculate anti-congestion tolls, will be in an upcoming post for the people who are truly interested.

Ridership

SMART South as envisioned would be built alongside a secondary transbay project extending Caltrain and some kind of heavy rail subway across the bay to Alameda County. These would happen regardless of SMART South, so its value is really in connecting the North Bay with the South and East. How many riders would use that link?

Last year, I examined what higher frequencies could do for the base SMART system’s ridership and arrived at a conservative 12,100 daily trips. Adding the southern Marin, downtown Novato, and Presidio stations would push the ridership up to 22,000 using the same model [7].

Using 2014 Census data, it appears that roughly 7,500 people live within a half-mile of SMART and SMART South stations and work within a half-mile of BART or Caltrain, or vice-versa [8]. While only half of them are likely to commute via transit after this extension, additional riders would come from outside the half-mile radius, and commutes only account for about 20 percent of all trips. Wrap all that up and we have another 50,000-80,000 trips per day, depending on fares, travel time, and transfers. Given that this range comes from a model that assumes no anti-congestion tolls - and that such tolls boost transit use – I’d lean more towards the higher than the lower number. That would nearly double the capacity of the Golden Gate and northern Highway 101 corridor.

Wrap-up

So for about $5.5 billion, paid for with new tolls and a 0.4% sales tax, SMART could dip south into San Francisco, fully tying Sonoma and Marin into the regional and statewide rail systems. It would provide a viable alternative to the freeway. Alongside tolling, it would make congestion a thing of the past in the North Bay, making deliveries more timely and commutes much more reliable.

This is merely a draft, of course, and should be subjected to more rigorous study. The political difficulties of yet another sales tax and yet-higher tolls are apparent. But SMART South is eminently attainable. With a little ingenuity and a little optimism about the future, it could be our next stop.

Footnotes

[i] Estimate from existing SMART costs.

[ii] Estimate from a variety of peer projects.

[iii] Assuming borrowing is on the same terms as MTC’s toll-related bonds and is spaced according to construction needs.

[iv] Assuming borrowing is on the same terms as SMART’s sales-tax backed bonds.

Works Cited

[1] David Edmondson, “The Science of Traffic and Its Awfulness,” The Greater Marin, July 3, 2017.

[2] David Edmondson, “Let’s Get into the Weeds: A Congestion Charge Plan for Marin,” The Greater Marin, July 10, 2017.

[3] Stephen A. Gazillo, “A Planner’s Guide to Fixed Guideway Electrification Projects,” Transportation Planning, November 2005.

[4] County of Marin, “Investigative Study to Begin on Alto Tunnel” (County of Marin, January 10, 2017).

[5] Charles Seim, Mark Ketchum, and T.Y. Lin International, “Golden Gate Bridge Mass Transit Feasibility Study” (San Francisco, CA: Golden Gate Bridge, Highway and Transportation District, October 1990).

[6] Railway Gazette, “Caltrain Signs Double-Deck EMU and Electrification Contracts,” Railway Gazette, August 16, 2016.

[7] Transportation Research Board, “Elements Needed to Create High Ridership Transit Systems,” Transit Cooperative Research Program (Washington, DC: Federal Transit Administration, March 2007).

[8] Center for Economic Studies, “Longitudinal Employer-Household Dynamics” (Washington, DC: United States Census, 2014).

Polishing poop: the SMART schedule

Update: SMART just reached out to me with news that they are looking at the schedule again based upon the feedback they've received, so stay tuned for a new schedule.

By now, word of the final SMART schedule is out, and the response is relatively negative. The schedule (PDF here) has a 90-minute gap right at the heart of the rush hour, between 7:26am and 8:56am. Folks were not having it on Twitter. These two tweets are fairly representative:

The SMART Board wasn’t happy with the results either. San Rafael Mayor Gary Phillips told staff at the meeting where the schedule was released, “With these kind of gaps I’m concerned people will say, ‘I’ll continue to drive my car,’ I would encourage we revisit this” (1).

For their part, SMART spokeswoman Jeanne Belding wrote me indicating the schedule was a result of a survey of potential riders after a draft schedule was released. She added, “The schedule we are opening with is based on previous feedback, our staffing, and takes into account the fact that we have a single-track system” (2).

SMART General Manager Farhad Mansourian indicated that the reason for the schedule is, in short, that it is complicated: with the system running as it is, a change to one train means all trains must be changed. And there’s freight trains to deal with, only four active passenger trains, and so on (1). But I think there is more to discover in the schedule, and that the system is not nearly as hamstrung as GM Mansourian seems to indicate.

Polishing poop

Let it be known that just because the schedule is bad doesn't mean SMART isn't operating under real constraints. Undoubtedly, this was someone's attempt to polish the poop (or shine the shit) that is their situation. Nevertheless, this is definitely not sufficiently shiny yet, and I think we can do better. Let's look under the hood at what we're dealing with.

First, we can divide the schedule into a series of what I call platoons: four trains, each departing 30 minutes after one another, followed by a minimum of a 90-minute break, followed by another platoon. These are set by the number of trains SMART can run at any given time: just four of their seven-train fleet. Spokeswoman Belding told me they have had trouble hiring drivers, citing the high cost of living as the reason, and so they are limited to just four trains on the tracks at any given time. She did not answer a question about when they expected to be at full strength (2).

Another limiting factor are the passing tracks. Taking best practices from Switzerland and Germany, SMART built a single-track commuter system with four four-mile-long passing tracks at key locations so trains could run in both directions and pass one another. The problem, of course, is that these passing tracks limit the schedule to certain ranges. What those ranges are, SMART can’t say, but we can assume that the schedule as presented is one solution.

Taking all this into account, we can trust that changing one train’s arrival or departure time more than a few minutes requires the rest of the schedule to be changed by the same amount.

Alternatives

So now, the problem at hand: what to do about that 90-minute morning gap.

I took this as gospel and rotated the entire schedule around the arrival time of Train 5 at downtown San Rafael. Here’s what I call San Rafael Rush:

The San Rafael Rush schedule gets everyone to downtown San Rafael before 9am and ensures people still have time to walk to work after the last train arrives. Unfortunately, it makes things tough on northbound commuters, giving very little flexibility for Marinites working in Sonoma.

The second option is what I call Early Bird:

This option pushes everything back by about 10 minutes, ensuring that the 90-minute gap ends right as rush hour is at its worst. I’m not so keen on Early Bird, as few people arrive at work during those early morning hours served by the first platoon, but it does make sure that people can at least get to the office by 9am.

There are other methods of making the schedule fit, but it’s important to understand that SMART is operating in a tension between what riders say they want versus what the data says they should do. Census data shows what we know: that a plurality of people working in San Rafael arrive between 8am and 9am, people whom the current schedule poorly serves. SMART also insists that its schedule is based upon feedback from its own scheduling poll of potential riders.

It’s also important to note that GM Mansourian’s statements that nothing can be done are obfuscation. True, SMART is limited in its schedule movement, and they will be until they get the drivers they need, but they can indeed do better than what they’ve given. There is a bit of hope on that front. The GM indicated they’d be open to changing the schedule based on feedback after the train has started running. “This is what we will test and get feedback. If we can tweak, we will tweak” (1).

PS - And just because you've heard it a thousand times already, I did promise to remind you not to risk getting hit by a train. Sure, they'll be far less dangerous than drivers, but that doesn't mean you want to be the guy making everyone late for work because you got squashed by a train. Also, I will take this opportunity to repost one of my favorite ads, Dumb Ways to Die.

Works cited

(1) Prado M. SMART schedule has major service gaps. Marin Independent Journal [Internet]. 2017 May 17 [cited 2017 May 22]; Available from: http://www.marinij.com/article/NO/20170517/NEWS/170519805

(2) Belding J. Service schedule & trains. 2017.

A high-frequency SMART corridor, revisited

In this week’s IJ Forum, guest and transit skeptic Richard Hall brought up something I didn’t expect: the argument that transit frequency equals freedom [1]. This is something that transit advocates have been harping on in Marin and elsewhere for years, and one of the key factors that is likely to hold back SMART from reaching its potential. Though I addressed this point back in 2012, with the train opening up this year it is worth revisiting how SMART might be able to reach higher frequencies, and how much it might cost.

There is blood in the single-track stone

Once operational, SMART’s trains will run in both directions simultaneously despite having only one track. It can accomplish this through the judicious use of passing tracks, meaning a strategic stretch of the corridor will be double-tracked so trains can pass one another.

At full build-out, from Cloverdale to Larkspur Landing, there will be 4 such passing tracks, each of which is 12 miles long, which will allow trains to run every 30 minutes in either direction. (This 30-minute time is called the “headway” in transit-speak.) To double the frequency to 15 minutes, we would need to double the number of passing tracks to 8. To double frequency again to 7.5 minutes, we would need to double the number of passing tracks again to 16.

At this point, the permanently single-tracked Puerto Suello Tunnel between North and Central San Rafael becomes the choke point. Any further increases would need to widen the Puerto Suello Tunnel and basically double-track the whole system. This would likely overkill for the foreseeable future.

Using the existing construction costs as a guide, the cost for the passing tracks on a 15-minute headway system is $60 million. The cost for a 7.5-minute headway system is twice that: $120 million [2]. If we include the cost of the trains needed to run such frequent service, the total cost would be $120 million and $307 million, respectively [3].

We can squeeze blood out of this stone if we are willing to spend the money for it.

Of course, ridership at this point becomes a problem. Is it worth it to run trains this often? Definitely.

There are almost 43,000 jobs and over 19,000 people within a half-mile of SMART’s stations. 2,237 people live and work within the station areas [4], but commute trips account for only about 20 percent of all trips, and this doesn’t include people who might use the park and ride services. Ballpark figures, using a ridership model [PDF] from the Transportation Research Board put the ceiling of SMART’s potential ridership at about 25,000 [5]. SMART itself estimates its ridership will be around 4,500 trips per day, which the model agrees with.

We need to dive a little bit into some wonky economics for a moment using these numbers but bear with me.

When a transit operator alters some aspect of a transit service, they of course also alter the ridership. Increase the vehicle speed and ridership goes up. Increase fares and ridership goes down. This is called the elasticity of demand: how much does a given change affect the demand for that transit service. The first example mentioned references the in-vehicle time elasticity because it indicates how much people change their habits based on how much time they spend in a vehicle. The second example is the price elasticity because it deals with the price of using the service.

Headways alter the access time elasticity, which is more valuable to people when it comes to transit. As much as you may enjoy your walk to the train, you probably enjoy the fact that you can work or sleep on the train en route a little bit more.

Access time elasticity among commuters is 1.28, which is pretty high. Decreasing average wait times by 1 percent by decreasing headways by 2 percent increases ridership by 128 percent [6]. Doubling SMART’s frequency to 15 minutes, then, will get us a 64 percent* increase in passengers: from 4,500 trips per day to about 7,380. Doubling frequency again could get us to 12,100 trips per day. This, of course, does not count the number of people who would use SMART for non-commute trips too, and it also ignores the effects of improving on the very infrequent service SMART is planning on providing in the middle of the day.

I would argue that a 15-minute frequency would absolutely be worthwhile on the basis of the commuters alone (the cost per new commute trip is $42,000, half the cost per trip on the baseline SMART system). A 7.5-minute system is not as cost-effective based on new commuters, but is significant if we include non-commute trips.

It may also be a viable alternative to a wider Novato Narrows. The traffic congestion there is in part due to a 15 percent increase in the number of cars travelling through to Central San Rafael, or roughly 500 more vehicles per hour [7]. Diverting 3,690 trips per rush hour (half of 7,380) would alleviate that congestion, at least until drivers fill up the space again thanks to induced demand [8].

So Hall is quite right on this point: transit frequency influences how people travel and how many people use the system. I am unsure whether he knew just how influential frequency can be, but no matter. SMART would do well to examine the effects of increasing its service frequency.

* Average wait times are half of the headway: if you arrive at a random point during the inter-train period, your average wait is half the full headway. Doubling frequency, then – a 100 percent increase – decreases average wait times by half that, or 50 percent.

Note: Given how off-topic any comments section can get in a SMART-focused article, I have turned them off for this post.

Works Cited

[1] Traffic in Marin, IJ Forums (San Rafael, CA, 2016).

[2] David Edmondson, “High SMART Frequency on the Cheap,” The Greater Marin, August 8, 2012.

[3] David Edmondson, “Can SMART Double-Track?,” The Greater Marin, August 6, 2012.

[4] Center for Economic Studies, “Longitudinal Employer-Household Dynamics” (United States Census, n.d.).

[5] Daniel G. Chatman et al., “Making Effective Fixed Guideway Transit Investments: Indicators of Success” (Washington, DC: Transportation Research Board, 2014).

[6] Arthur O’Sullivan, Urban Economics, 8th ed (New York, NY: McGraw-Hill/Irwin, 2012), 295.

[7] David Edmondson, “The 101 Corridor: Transportation Myopia in Practice,” The Greater Marin, January 13, 2013; Caltrans, “Traffic Volumes on California State Highways” (Sacramento, CA: Government of California, 2014).

[8] Connor Jones, “The Street Economics of Induced Demand,” The Greater Marin, December 21, 2015.

Bad shuttle routing will make SMART's last-mile problem worse

Shuttle service to SMART’s temporary north end will be winding, slow, and inefficient. That’s bad news for Sonoma’s towns, which are already under strain from car commuting.

Waiting for the Bus. Image by Franck Michel, on Flickr.

Waiting for the Bus. Image by Franck Michel, on Flickr.

Sonoma County is getting passenger rail service for the first time in decades, hopefully starting at the tail end of 2016, with the opening of the SMART train.

SMART is starting to move from being an agency building a train, to an agency that will *run* a train. Big difference. Based on a lot of things I have heard in the past, there is concern that General Manager Farhad Mansourian is a better project manager CEO than an operations CEO. Time will tell, but as we approach the opening and decisions start to fall in place, I am going to reload this blog and follow the topic.

At last month's SMART board meeting, there was a presentation on First/Last Mile connectivity. The PDF is linked above, there is also avideo of this meeting - March 2, 2016 which is interesting and a bit illuminating. The board rightly gives the staff of SMART and the related agencies credit for a lot of hard work, but there are a lot of holes in the strategy which underscores that transit agencies and boards don't really focus test their ideas. They look at a problem, place themselves in the problem, and imagine how the problem needs to be solved. Witness Caltrain discussing workers who can go in "later" because they have "flexible" schedules. They go to work 8-5, my office doesn't even turn the lights on until 9 AM and people get upset at meetings before 10. The schedule isn't "flexible", it's flat out different.

With SMART, the board (mostly local politicians) and staff are working from a very "how do I get to San Francisco" mindset. I can't blame them, a lot of the public reacts this way as well, if you read internet comment boards. Officially, SMART diverges from this message on their website:

Today, more than 75% of commuters in the North Bay travel either within or between the two counties to get to work.

Thus we get to my first topic on the presentation on first/last mile - the North County Coordination to be provided by Sonoma County Transit. This connection is at the direction of the board and not negotiable - Windsor, Healdsburg, and Cloverdale were on the original proposed train line, and have had train service delayed indefinitely due to lack of funding. There is a bus from Cloverdale to Santa Rosa - route 60 - but it's slow compared to the freeway and doesn't go to the train depot on Airport Rd. SCT is going to add a shuttle - as seen in the first/last mile presentation, that will express between the 3 towns and the North SMART terminus at Airport Road. It will mostly run on US-101 in uncongested areas making it a quick connector. Sort of.

The proposed schedule shows the "go south in the AM, north in the PM" mindset of SMART. The only shuttles in the AM run North to South to meet trains, there are no proposed shuttles the opposite direction. One problem - the City of Healdsburg is a net *importer* of labor, not an exporter! SMART is trying to figure out how to get a small population of Healdsburg residents south, instead of the large population that is trying to get TO Healdsburg. The population shift during the day is such that tiny Healdsburg is starting to have parking wars and is now considering using valuable downtown land to build more parking.

Healdsburg has over 4,500 in-commuters and over 3,700 out-commuters. This relatively large shift in population for a town of just 11,000 during the workday is exacerbating housing and parking constraints.

Healdsburg has over 4,500 in-commuters and over 3,700 out-commuters. This relatively large shift in population for a town of just 11,000 during the workday is exacerbating housing and parking constraints.

Housing prices in Healdsburg are forcing the town's workforce to leave the city for Santa Rosa and Cloverdale, less expensive areas, which is bad on its own, but exacerbates the parking problem which leads to bad land use decisions which feedback to make the housing problem worse. That workforce could theoretically take SMART to the Airport and hop a shuttle to town, but it won't exist.

Not only does a northbound shuttle not exist, but the market of workers in Cloverdale who could take the shuttle to Healdsburg will be poorly served. The express shuttle will go from Cloverdale to Healdsburg in 20 minutes. SCT route 60 takes ~40 minutes to make the same run - the express cuts the trip in half and could attract new riders. However, because SMART and SCT are only thinking about "get people to the train" - the stop is located at the decrepit Healdsburg train depot on the outskirts of town (and they are building a $1 Million parking lot there), producing a walk for people making that trip which eats up any time savings. It also means that any tourists from SF who decide to take this route get dumped off in the middle of nowhere instead of the middle of town. Might as well drive. This in order to provide park and ride service to a bus for Healdsburg residents? The Healdsburg depot is out of the way for most Healdsburg residents, the bus will make an additional out of the way stop at the Windsor "Train Depot", before winding to Airport Road. Summary - any sane Healdsburger with a car will simply drive to the Airport Road Station.

The detour through HBG to get to the old depot, and the similar winding trip in Windsor kills the trip time, reducing any incentive for people coming from Cloverdale to use the shuttle. The buses should make quick stops just off the freeway but close to the downtowns - the Amtrak bus stop at Mill/HBG Ave in Healdsburg, and right off the freeway in Windsor next to where there is a McDonalds. Shuttle service like this relies on speed. Optimizing it is the only chance to get the ridership needed to keep the shuttle going and hopefully support the train. This includes understanding that some of the riders will eschew the train altogether, using the shuttle as a fast intra-North County bus service. And they should provide service in both directions at both peaks.

Original Post: Murphy, John. 2016. “SMART Train - Last Mile Connectivity - North County.” Holier than You Blog. March 31.

Other Works Cited

Healdsburg, CA. 2016. “Cerri Site (Purity Building) Redevelopment Project.Healdsburg, California Official Site. Accessed May 29.

Mason, Clark. 2015. “Mass Evictions in Healdsburg Prompt Cries of Racism.The Press Democrat, July 8.

Michel, Franck. 2014. Waiting for the Bus. Photograph.

Sonoma-Marin Area Rail Transit. 2016a. Board of Directors Meeting: March 4, 2016. Petaluma, CA.

———. 2016b. “First/Last Mile Connection.” Petaluma, CA, March 2.

U.S. Census Bureau. 2016. LODES Data. Longitudinal-Employer Household Dynamics Program.

SMART Train alcohol policy comes up short

SMART wants to limit alcohol on its trains to only what patrons buy at the concessionaire. Experience from Caltrain shows that allowing riders to BYOB policy is not just good policy, but helps embed the system further into the culture of riders. 

Caltrain riders hanging out. Image from SF2G.com

Caltrain riders hanging out. Image from SF2G.com

For 18 years I have ridden Caltrain - and in that time I have brought aboard and consumed hundreds of bottles and cans of beers, which I have enjoyed legally on the train. This includes frequent patronage of the semi-official Party Car formed by the cyclists on Caltrain.

Starting in 2000, alcohol consumption on Caltrain increased exponentially with the opening of AT&T park, home of the San Francisco Giants. Giants fans have flocked to the train, riding up the Peninsula with cases of beer and bottles of who knows what, safely being carried to and from the games. At some point, Caltrain decided to ban alcohol on trains running after 9 PM only IF there is an event - primarily Giants games but also Sharks games, concerts at AT&T Park, and now 49ers games and concerts at Levi's Stadium. That late, the consumption before and during the events reach enough of a pitch that it was prudent to put a limit on the policy. Over the years the train has also served hugely alcohol-fueled events like Bay to Breakers, Hardly Strictly Bluegrass, Octoberfests, etc... frequently on the same day.

Generally speaking, this open BYOB policy on Caltrain has been a success. Problems are generally very rare, given the nature of the train as primarily a commuter rail with a higher level fare. It has been an attraction to the train that has a nominal positive influence on overall ridership numbers.

At the end of 2016, I will start riding a new train line - the SMART train in Sonoma County. It will function as primarily commuter rail, running almost exclusively during peak commute hours, with a fare structure prohibitive to general miscreants, making it nominally similar to Caltrain, except that it will serve no special events like the Giants as there are no major sports or entertainment venues on the train line.

SMART has released their draft code of conduct for the train. It includes a policy of NO BYOB. They don't have a no alcohol policy because they have an operating theorem of having a bar car on the train. I am very disappointed by this policy - I find it rider hostile and that it will have a negative impact on the rider experience and overall ridership. While there will be a bar car - there are bar cars on the Amtrak Capitol Corridor too, but in a place like Sonoma County with an excellent selection of beer and wine, to limit riders to the meager selection of a bar car is misguided.

There is, of course, the suspicion that the rationale is not to prevent unruly behavior, but to support whatever vendor they get for their bar car. This is understandable, for the most part because the decision to put a bar car onto the trains is misguided at best. SMART put out a presentation on the bar car where they are toying with giving free rent to the vendor for a return of a percentage of the profits. This is predicated on the presumption that a bar car will turn a profit - my experience from the Amtrak Capitols is that the bar car is at best a loss leader, not a profit center. This is especially true when you consider that SMART has wasted valuable train space to build the bar car.

I personally think that the potential ridership of SMART should make it clear that the no BYOB policy is not in line with the overall goals of the train. They should reconsider this path and allow riders to bring their own beverages onto the train.

If you agree - please email SMART at info@sonomamarintrain.org.

Originally Published: Murphy, John. 2016. “SMART Train Alcohol Policy.” Holier than You Blog. May 18.

Source: http://holierthanyou.blogspot.com/2016/05/...

SMART's new shelter designs are even worse than before

SMART may be on the verge of making a serious mistake. Back in August, 2014, the rail agency released its “65%” plans for stations to decidedly mixed reviews. Stung by the criticism, particularly from San Rafael mayor Gary Phillips who called the designs “ridiculous”, SMART went into a long internal huddle.

Shelter Option 1, from SMART’s “65%” station design
Shelter Option 1, from SMART’s “65%” station design

Last Wednesday, at its Board meeting, SMART offered something new. Focusing mainly on platform shelters, it proposed an alternative to the forest green “Option 1” design included in the 65% station drawings.

The new shelters, inspired by bus stops, use a “standing seam hip roof design” and are being referred to as “Option 2”. They are proposed to be painted black, although SMART staff seems willing to allow cities to paint them any color in the rainbow. Cities will have until March 31st to tell SMART whether they want this new shelter or prefer to stick with Option 1. Based on the feedback from SMART Board members, it appears that cities will be lining up for Option 2.

An inspiration for “Option 2” – Bus shelter in Duluth, MN
An inspiration for “Option 2” – Bus shelter in Duluth, MN

That’s unfortunate. The new Option 2 design has many serious downsides and will likely be viewed with regret once SMART begins its operations. Moreover, switching them out for something totally different later on may not be easy.

SMART is waiting until the shelters are chosen to lay a top slab of concrete on its station platforms. That implies that the details of the top slab (for things like utilities or drainage) are tailored to a specific shelter type. A switch to a different shelter in the future might require demolishing the tops of platforms, which would be costly and time-consuming. Given that, it’s far more critical for SMART get this decision right than it would be for a typical bus operator.

So what’s wrong with Option 2? Several things. A good rail platform shelter should have the following characteristics:

  • A very narrow footprint and open design to avoid getting in the way of customers circulating on the platform.
  • A broad canopy with an appropriate height to maximize weather protection; and
  • A nice aesthetic that is compatible with its surroundings.

Option 2 misses the mark on all of these.

Shelter Footprint

Space on SMART’s platforms will be very limited. It’s “side” platforms will be 15 feet wide, while its “center” platforms (set between two tracks) will be 18 feet wide. Let’s consider the larger of these two.

Center platforms will have two, 24 inch wide, nubby, tactile warning strips; one along each platform edge. That leaves about 14 ft. of room for patrons, or about 7 ft. on each side of the platform. With shelter Option 1, the footprint will extend about 2 ft. out from the platform center line on each side, leaving two, 5 ft. “travel lanes” on each side of the shelter. That’s manageable.

By contrast, the Option 2 shelter is much, much wider. It will extend a full 4½ ft. out on each side of the platform center line, leaving a very narrow 2½ ft. on each side of the shelter. That’s untenable.

A visual simulation on a PowerPoint slide from SMART’s recent Board meeting shows the full horror of this future condition (1:04:47 mark).

Screen capture from SMART PowerPoint – Feb 18, 2015 Board Meeting
Screen capture from SMART PowerPoint – Feb 18, 2015 Board Meeting

To make matters worse, the narrow 2½ ft. width between shelter and warning strip isn’t just a single choke point that customers will have to navigate around. The Option 2 shelters are only open one side, meaning that the “closed” side will present a long, continuous, 2½ ft. channel between platform edge and the solid glass wall of the shelter. SMART is proposing to ultimately add two or three of these monster shelters to each platform.

Suspended four feet in the air, SMART platform’s will be narrow islands, sometimes crowded with people, and far more populated with bicycles, wheelchairs, strollers, and luggage than a typical bus stop. The Option 2 shelters are going to pose great difficulties to circulating customers when SMART is in operation. While they may not violate the letter of the Americans with Disabilities Act (ADA), they certainly violates the spirit of it. Amazingly, only one SMART Director (Russell) raised any concern about space constraints.

The green Option 1 shelters will allow for far more space on the platforms. However, SMART’s 30% station design shelters had a key advantage over both Option 1 and Option 2. They were porous. They did not have a continuous wall of windscreens separating one side of the platform from the other. This openness would allow for more platform space and for customers to freely move from one side of the platform without having to go all the way around a bulky and long shelter.

SMART 30% Station Design
SMART 30% Station Design

Weather Protection

At Wednesday’s meeting, SMART Director Kellner speculated that the Option 2 shelter would offer better weather protection than Option 1. In fact, the opposite is true. The canopies of the Option 1 shelter span 12 ft., while the heavier canopies of the Option 2 shelter only span 10 ft. and provide less coverage.

Moreover, the Option 2 canopies only offer weather protection on one side, according to SMART’s drawings. On the “closed” side of the shelter, the roof only extends a few inches over the wall of long glass, which will offer no weather protection at all.

The one-sided and enclosed nature of these bus stop shelters prevents customers from easily and casually ducking under the canopy on a rainy or hot sunny day. They have to deliberately and consciously move into the enclosure on one side, squeezing through the 2½ ft. wide choke point.

Aesthetics

Much of the politicians’ comfort with Option 2 seems to stem from the look, which avoids garish green paint and offers a more familiar shape. In the words of SMART Director Mouton-Peters, it “fits the cultural ethos” of Marin. The new shelter design was reportedly partly inspired by the shelters at the San Rafael Transit Center.

While beauty is subjective, I doubt most Marinites cherish the Bettini Transit Center’s shelters. Without a doubt, the most beautiful things in Marin County are inherent in the place itself: the green and gold rolling hills, the oak trees, and the historic town centers.

The best thing that a transit shelter can do in this environment is to stay simple and clean and get out of the way. SMART Director Rabbit offered some of this perspective when he wondered if these big, black, bus shelters might end up blocking views of more cherished places and structures near the stations. They will.

Little House on the Platform

A misguided approach on shelter design can begin easily enough. When most people think of a “shelter”, the most comforting image that comes to mind is a house. Then, when people think of an iconic shape for a house, the most classic vernacular is a triangular pitched roof. In fact, SMART staff noted that the new Cotati Depot building also partly served as an inspiration for the Option 2 shelters.

Unfortunately, a triangular roof that drains water into gutters on either side tends to be very heavy. It’s not structurally possible to cantilever the canopy very far. Moreover, the weighty triangular roof can’t be supported easily by narrow support columns in the center. It requires a much wider base, just like a house. That leads to bulk. The problem is that rail platforms are not spacious enough to accommodate a bulky “house” while also serving the increasingly complex function of patron circulation and access.

Lessons from Utah

In the 1990’s, Salt Lake City was part of a wave of light rail development in the United States. Some of the TRAX light rail stations, however, were designed with wide, black, bulky shelters that look remarkably like what SMART is now proposing. The result was difficulties with customer circulation and safety on the platforms. Trolley Station in Downtown Salt Lake City, pictured below, is a textbook example of excessive platform clutter.

Trolley Station – Salt Lake City, UT
Trolley Station – Salt Lake City, UT

Perhaps trying to moving past this mistake, the new shelters proposed for the 2013 North Temple Bridge/Guadalupe Station (which serves both light rail and commuter rail) in Salt Lake City are decidedly different. The design by Hatch, Mott MacDonald, offers some excellent characteristics.

SLC Trolley 2
SLC Trolley 2

First, the shelters are narrow at the base to avoid clutter and to allow for easy circulation and safety. They are porous to allow movement from side to side. They have wide spanning canopies for good weather protection. They drain to the center, so that water doesn’t land on passengers’ heads. They allow for some natural light to come through, are simple, and basically get out of the way to allow for views of mountains and cityscape. And lastly, the name of the station is positioned below the canopy where it can be read easily by people on the platform and in the train.

SMART’s Option 2 shelters literally offer none of these important features.

Where to Go Now

For SMART, it’s been a continuous climb down on stations. They began with a professional design led by an architecture/engineering firm with transit experience, not unlike Hatch, Mott, MacDonald.

Then, SMART turned the design of stations over to its construction contractor, Shimmick. Now, they spear to be doing something even worse, taking hail-mary design advice from the Sonoma County Transportation Authority (SCTA), a funding agency with no transit operations, railroading, or architectural experience. It’s the SCTA who suggested the Option 2 bus shelters.

Cities along the rail line should not take the SCTA’s recommendation and should rally around shelter Option 1 for the good of the SMART’s system. While imperfect, it at least avoids the serious problems presented by shelter Option 2. If painted a more neutral color than the proposed forest green, it could be a respectable piece of station furniture.

Of course, while it may be too late, the best long-term outcome for both the riding public and taxpayers would be for SMART to implement a truly professional shelter design that considers the myriad details of the customer experience.

The SMART station debate: who’s right?

2014's 65% design SMART’s “65%” designs for stations were recently unveiled and promptly criticized by some politicians, pundits, and the public for lacking amenities and inspiration. On the other hand, SMART has been defended by other elected officials and commentators for its frugality.

So which side is right? Both.

SMART has made some sound decisions with its stations, but it may also be blowing an important opportunity.

SMART’s good moves

Those who expected SMART to build new depot buildings or to occupy existing historic ones haven’t been paying attention.   The rail agency never promised to do those things. Depot buildings are nice but aren’t needed for contemporary rail services.

The same goes for bathrooms at stations. They were never promised by SMART, and the rail agency wisely opted to put them on the trains where they are more practical and won’t become a maintenance and security nightmare. Any attempt to bring bathroom back to the stations would be an expensive mistake.

SMART has also been unfairly knocked for its four-foot-high concrete platforms, mostly notably by Dick Spotswood, who called them “boneheaded” and blamed a previous SMART director. The concern about platform bulkiness is justified. However, to imply that there was an easy or cheap way around them is misguided.

The platform height was driven by SMART’s choice of a Diesel Multiple Unit (DMU) train that meets federal regulatory requirements, but had four foot high floors. The Japanese vehicle was reportedly $20 million cheaper than the next closest competitor, which had roughly two foot high floors. Spending millions more on a different type of train just to have platforms that were two feet shorter might have been tough to justify, which is why the SMART Board didn’t do that. It’s unlikely that the current SMART chief would have recommended any differently.

SMART’s weaknesses

Still, despite making reasonable calls on depots, bathrooms and platform heights, SMART’s current station designs are a functional and aesthetic disappointment. As a defense, SMART staff recently gave its directors a PowerPoint show complete with dull and bare rail station platforms. The message? Others have uninspiring stations too. By comparison, we are not so bad!

In reality, many rail agencies in the United States give serious consideration to passenger amenities and station design. They view bike parking in both racks and lockers as essential features, as seen here, here and here. Or, they have architectural appeal, as seen here, here, and here. Or, they have landscaping, real-time information, good signage, or clever lighting plans.

In 2011, SMART developed station concepts with input from the public. That process was not a boundless invitation to imagine “dream stations” as some revisionists have recently implied. In fact, the designers at the time conservatively suggested that platforms use the same elements across all stations for brand identity and ease of maintenance. Moreover, the original designs were not radically different from the current ones, in that they envisioned simple platforms with a few key elements. However, they did pay attention to some important details.

The 2011 SMART station design

Fist, they attempted to soften the stark visual impact of the four-foot concrete box platforms for better aesthetics, to minimize a large and blank graffiti canvas, and to improve safety in case of a passenger fall. This was done with planters and broad staircases on the backside of platforms. The current design ditches those things, and for safety will rely on a guardrail on the backside of platforms. It’s not clear what that guardrail will look like since it’s absent from simulated image of the 65% design. The simulation also gives a poor indication of just how high and bunker-like the platforms are going to be.

The original designs had shelters with better dimensions for weather protection. At roughly 7 feet high instead of 9 feet high, they were better equipped to keep the rain out, and were longer to protect more people. They were designed with power connections and mounts on the underside for lighting, speakers, security cameras, or other elements that SMART might need in the future. The new shelters merely shift those considerations and costs to the jerry-rigged future.

The original designs included both bicycle racks and lockers, real-time information, a more thorough signage and lighting plan for safety and security, and more attractive aesthetic.

In the face of arguments that better options exist, including those already developed by SMART itself, some SMART staff have responded that they simply can’t afford it. To make up for perceived short-comings, however, SMART is allowing local jurisdictions to pay for improvements themselves.

This approach is short-sighted.

Better design can be worth it

Passenger amenities probably represent around 1% of total project costs. Reducing the quality of these elements produces a tiny fraction of savings. Moreover, to create new generic designs, SMART had to pay consultants AECOM and FMG Architects, reducing savings further. A very small amount is being gained the short term by giving up attention to detail and a lot could be lost in the long run.

Having quality elements at stations should be thought of as a revenue booster. While SMART’s operations will be subsidized, the rail agency is still expecting few million dollars from passenger fares each year. Over twenty years, that expected money totals well over a hundred million dollars. To capture those dollars, SMART will need riders and to capture riders it will help to create a positive impression. A very small amount of money invested in quality stations now, combined with a better approach to design quality, will buoy revenues later on.

If trains can be nice, why not stations?

Some have suggested that SMART should strive for “bare bones” minimalism. However, this philosophy stands in stark contrast to SMART’s decisions about its trains. The rail agency is spending hundreds of thousands, or perhaps in the low millions of dollars, to make the noses of its trains swooped instead of flat and to paint its trains green. Is this a waste? No. The trains will define SMART for a generation. It is common sense (and de rigueur in the private sector) to put at least some portion of a product’s budget into to making that product appealing to consumers. This principle being applied to SMART trains should also apply to its stations.

Beyond the imperative of attracting riders, SMART also needs to keep the general public supportive of its project, including those who will never ride. At some point in the future, SMART will need to re-authorize its quarter cent sales tax to continue running its service. If station are a source of community pride, instead of a sore spot, it will make that task considerably easier.

Cities pay more, but for what?

For local elected officials who understand the importance of good stations and want something better the road ahead is blurry. SMART has offered to allow cities to pay for upgrades, but it’s not clear what that means in practice.

It would be wildly inefficient for multiple cities to hire their own consultants to re-design stations. It could also result in a crazy hodge-podge that detracts from a consistent SMART identity. Allowing cities lots of freedom to customize platforms could force SMART to assume maintenance responsibility and liability for a host of elements that it didn’t choose or design. It also might also force SMART to incorporate station features at a very late date, which would add cost.

To cut down on these risks, SMART could control the process by developing station upgrades itself and then offering them to cities for a price. This would certainly be more coherent and cost-effective, even though it would ironically involve SMART paying money to consultants to do station design work for yet a third time.

Either way, the decision to let cities customize stations is raising expectations far more than the first round of station design work in 2011. That process focused on coming up with a quality template that all jurisdictions could live with while keeping designs fairly consistent for SMART’s long term benefit. The new process offer a weak design but implies that anything might be possible for cities, as long as they pay. In the end, either SMART could end up with long-term station headaches or cities could end up with frustratingly limited choices.

Re-thinking the approach

All of this highlights the wisdom of doing stations right in the first place. In retrospect, developing a design with input from the public and local jurisdictions a few years ago was a prudent way of avoiding today’s disappointment, political grief, and extra consultant work. At the moment, however, SMART seems to view discussions of its station designs as a hassle rather than an opportunity.

While financial contributions from cities would be helpful, SMART has a political and financial incentive (and a small window) to do stations right. Consequently, it should take the lead in developing better designs, whether it involves dusting off the older ones or coming up with new ones. That effort should involve transparency, input from cities, a rabid attention to details, and a design that’s focused on SMART’s balance sheet over the long run.

High-speed SMART

"Unit 395008 at Ebbsfleet International" by Sunil060902 - Own work. Licensed under CC BY-SA 3.0 via Wikimedia Commons. The trains SMART will use are relatively slow. While they have a top speed of 79 miles per hour, their federally-mandated tank-like structure means a very long acceleration and long deceleration. Each stop will be a significant time suck.

In 20-30 years, when SMART replaces its trains, it may have a chance to do things differently. How much speed could we realistically wring out of the SMART system? Quite a bit.

The fastest commuter trains on the market are the British Rail Class 395, nicknamed the Javelin. They operate around London and - for the nerds - have a maximum operating speed of 140mph, compared to 79mph for SMART's trains.

With these trains, which would involve electrifying the tracks and upgrading them to 140mph for the low, low cost of $978 million or so, SMART will be able to make the trip from Cloverdale to Larkspur Landing in about 49 minutes, down from 93 minutes. Novato to Larkspur would be, of course, quite a bit less – just 11 minutes, down from 27 minutes. Exact times might vary based on dwell - how long the trains wait for people to get on and off.

Fast SMART

For Sonoma commuters, the Santa Rosa-Petaluma trip would be cut to 12 minutes.

If SMART soars over the Golden Gate, down Geary, and to the Transbay Terminal (for just $5-10 billion more!), travel times will be significantly cut there, too. From Transbay, it would be 6 minutes to Sausalito, 18 minutes to San Rafael, 26 minutes from Novato, and 68 minutes from Cloverdale. This includes local subway stops along Geary. Depending on how

A super-fast SMART, in other words, would fully integrate the North Bay into the rest of the Bay Area. That it would beat drive times along the entire 101 corridor would provide a powerful incentive to leave cars at home. It would transform the whole North Bay.

Despite that, as my statements about the high cost of this upgrade may betray, I'm not keen for this. The Bay Area has significant transit needs, such as BRT on El Camino Real, the evolution of Caltrain into a mass transit line, Dumbarton Rail, a second Transbay Tube, and, of course, the Geary Subway. Each one of these is huge and expensive, and each of them serve more people than SMART.

But it is interesting to imagine how transformative SMART could be with the right equipment, and the right rails.

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Planning for Reality check: Larkspur conspiracies

Image from Planning for Reality The Larkspur Landing Station Area Plan (SAP) is all the rage nowadays, and for good reason. People apparently don’t want to see any development or any changes to their community, and it looks like the development aspects of the plan are heading to the dustbin.

But there’s a myth Richard Hall, a leader in anti-development circles and writer of Planning for Reality, told me about yesterday on the IJ. He said the Larkspur SAP was necessary so SMART would get funding. Let’s fact-check this gem.

The claim

Under the Metroplitan Planning Commision’s (MTC) Resolution 3434, a commuter rail line like SMART can only get regional funding if it has an average of 2,200 housing units with a half-mile radius of its stations. MTC is in charge of dispersing regional funding from a variety of sources, and it’s entirely in its prerogative to disperse funds how it sees fit. Resolution 3434 is intended to promote transit-oriented development around train stations to limit sprawl out into the East Bay hills, farms, or elsewhere far from anything.

SMART, Hall claims, does not meet this requirement and needed to add 920 housing units around Larkspur Landing to qualify for MTC funding. Somehow Larkspur got involved, developed the plan, and now we’re headed for a train wreck of a plan.

The reality

There are a number of problems with this claim, highest on the list being that SMART has already qualified for regional funding under Resolution 3434. In fact, it was determined 4 years ago, in December, 2010, that SMART qualified for regional funding. SMART has since received funding and is using it to fund construction.

The finding was that SMART, excluding Corona Road and Novato North stations, had 15,251 housing units built or planned within a half-mile radius of its 7 planned stations. This is 99 percent of the required 15,400 units, and it was deemed sufficient.

Including Corona Road and Guernville Road, which was not the chosen plan MTC approved, there were 17,295 housing units out of 17,600 needed. It’s close, but not quite there.

Let’s say nothing happens in Larkspur except for a new station is built there. Let’s also say the planned Sonoma County Airport station is built and that SMART decides to open Corona Road. This means SMART will have 12 stations on tap, which means it needs at least 26,400 housing units within a half mile of its collection of stations.

Since I can’t find data on housing around either Novato North or the Sonoma County Airport, I’m going to say those have 0 units, just for the sake of argument. Adding up all the rest of the existing housing units gets us 19,796 housing units, well short of our needed 26,400.

However, San Rafael, Santa Rosa, and Petaluma have all completed station area plans. San Rafael plans for 272 more units downtown. Petaluma plans for 1,716 more units downtown and 523 more around its northern station. Santa Rosa plans for another 3,409 units around its downtown station and 2,680 around its northern station. This gets us to 28,396 total units, or 107 percent the needed amount.

A Rohnert Park SAP is also in the works, but it hasn’t been completed yet.

If there is a conspiracy afoot to get SMART to qualify for more regional funding through a Larkspur SAP, the conspirators are really bad at math. But if the author of Planning for Reality, a computer programmer, is similarly bad at math, perhaps we shouldn’t be so hard on them.

In sum: Hall’s claim is false.

What if there were no SAPs at all?

It’s important to note here that, when presented with this information, Hall shifted his tune both in email and online, choosing to criticize Sonoma for implementing SAPs and saying it was part of a bigger conspiracy for regional funding for construction. He also asked whether Larkspur Landing could have been included if no SAPs had been passed.

This question poses a highly improbable set of circumstances. First, Sonoma cities actually want to change, Rohnert Park especially. They believe their future lies in their downtowns, in the kind of places that Marin takes for granted. It is extremely likely they would have planned around their stations even if there were no MTC grant money, and likely would have planned even if SMART never existed.

Second, it was Larkspur, not SMART, that applied for SAP grant money. Anti-development activists believe MTC and SMART colluded to pressure Larkspur into taking that money against their will years before the Larkspur Landing station seemed possible. This was, they claim, to allow SMART to qualify for regional funding, even though it had already qualified for said funding.

But let's indulge them. Adding Larkspur Landing would have dropped the number of housing units from 99 percent of qualifying to 94 percent. However, as link of regional significance, it would be extremely unlikely that MTC would have allowed this to disqualify SMART. It was still largely in line with Resolution 3434, and there would have been strong pressure to keep the funding.

But there were SAPs passed, and SMART is going to open with 10 stations, not 7. It can easily add Corona Road for 11, and it looks like Larkspur Landing will open in 2017 for 12 stations. But perhaps we should forgive SMART for building itself. After all, it was voters - a more insidious force than any regional body - who put them up to it.

SMART will be a net negative on greenhouse gas emissions

The SMART train, now under construction, was marketed to voters as a climate change solution, and a rough analysis of the initial operating segment seems to substantiate that claim. Unfortunately, the advantage evaporates with the inefficient second operating segment to Cloverdale. Critics have decried everything about SMART, but one of the most pernicious ones that has remained unexamined was the critique of SMART’s fuel efficiency. At only 1.1 miles per gallon of diesel fuel, the cars seem like the height of inefficiency. How could SMART claim its operations would reduce transportation greenhouse gases when it’s so clear it won’t?

SMART’s initial operating segment, from San Rafael to Santa Rosa, will serve 28.5 million weekday passenger miles every year and travel about 332,000 miles doing it.* At 1.1 gallons of diesel per mile, that means it will get about 42.8 passenger miles per gallon (pmpg). Since diesel emits more CO2 per gallon than gasoline, we’ll need to revise it down to the equivalent of 37.4 passenger miles per gallon (pmpg-e), roughly the same as a hybrid. Not bad.

According to MTC, cars’ fuel efficiency will get up to 32.2 mpg over the next 20 years. But this is the sticker value. Realistically, cars get about 13 percent less mileage than that (according to Consumer Reports), and in stop-and-go traffic it can be cut down another 40%. With 1.2 passengers per mile, that adds out to 26.9 pmpg during commute hours.

In other words, SMART will very likely emit fewer greenhouse gases than the cars its trips will replace, at least for the initial operating segment (IOS). The full line, however, won’t be quite so great.

The IOS is actually the most efficient part of the SMART line, at least according to official ridership figures. Adding extensions to Cloverdale and Larkspur will lower the train’s efficiency by quite a bit, to 26.3 pmpg-e. This is only as good as a car. We can cross off the full system for greenhouse gas emission reductions, at least if CAFE standards have anything to say about it.

Had SMART not been so financially constrained, it might have pursued electrification from the beginning, a $70 million investment that would have provided cleaner (and faster) service to the corridor.

This is not an indictment of the SMART system. It does not measure how the system will encourage people to swap car trips for walking trips, which happens when people use transit. It also does not take into account the annual mobility benefits for users, which will likely be worth hundreds of millions of dollars per year.

Indeed, individual transit lines are not meant to be climate change solutions on their own. They are like fax machines, enhanced by and enhancing other lines nearby. The accrued benefit of the network, as a whole, is enough to change how people live and travel. And that is what the SMART effort is about: not a final solution to our carbon footprint, but another link in the chain.

*People have complained that the Dowling ridership estimate was overoptimistic, and was not “accepted” by the SMART Board. Given that the latest numbers are used in financial planning and therefore underpin much of the financial structure of the system, I’m more confident in them than speculation from critics. However, if you wish to reduce ridership by some percentage, the precise weekday passenger miles estimate is 28,457,926 per year, assuming 265 working days.