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Submission to the C-Tran board May 21, 2013



1.  Observations on CRC’s answers to questions from the C-Tran board.

Many CRC answers avoided answering the question, while answers about tolling and accuracy of predictions were misleading.

2.  Average weekday rail ridership projections, historic performance - a more complete version of CRC’s Attachment C. Shows ridership generally came in significantly below the estimates in the FEIS which is the current state of the CRC project.

3.  Cost projections Vs Actual in Millions of $ - a study of the accuracy of Trimet’s cost projections showing 0-37% cost overruns compared to the FEIS which is the current state of the CRC project.


4.  Oregonian article on Trimet hiding information in a lawsuit over a Trimet bus killing two pedestrians while making an illegal turn. Says Trimet trained drivers in making illegal turns.

5. Correcting False CRC claims - Corrects some of the false claims being distributed by CRC supporters.


Submitted to the C-Tran board  May 21, 2013:

Some Unanswered C-Tran Board Questions (plus a few comments)

(In the order of the “Partial DRAFT Response to Questions Submitted

by C-TRAN Board May 14, 2013 Special Meeting, May 13, 2014 which can be downloaded from

City of Washougal - Connie Jo Freeman

1. Is "light rail" required to obtain federal funding, or will "bus rapid-transit" suffice?

Comment: This is a simple YES or NO question. Please provide that, or at least include a simple yes or no statement somewhere in your lengthy answer.

City of Vancouver - Larry Smith

3. Question on timing - is it necessary for the operations and maintenance funding plan to be in

place by October 2013?  

Comment: Again, this is a simple YES or NO answer. Please provide that, or at least include a simple yes or no statement somewhere in your lengthy answer.

Cities of La Center/Ridgefield - Jim Irish

6. Show a representative year when tolls were levied on the existing bridges and compare to CRC

estimates for proposed tolls.  

CRC answer (last part only):

For the Final EIS, the range of one-way toll rates studied for the financial analysis was $1 to $3 (2006 dollars, see Exhibit 4.3-3 from the FEIS).  Assuming a 2.5 percent annual inflation rate, this  range in 2013 dollars would be $1.19 to $3.57.

Comment: FEIS Page 4-19:

Given the baseline financial assumptions used in this FEIS, finance  plan scenarios based on either the Base (Schedule 1) or Schedule 2 toll rates  do not appear to be viable. The finance plan scenario shown assumes Toll Rate  Schedule 3 and employs its entire borrowing capacity. It employs 3 years of precompletion tolling on a cash basis and a small amount of residual toll revenues. (Emphasis added)

Comment:  The CRC answer is deceptive because Schedule 3, the minimum viable toll, shows a toll of $3.00 during rush hour in 2006 dollars. When adjusted per FEIS instructions (2.5% increase per year) one gets $4.14 (about $2000/yr) in 2019, the year of opening, not the stated $1.19-$3.57 toll.

The CRC also forgot to mention The Columbia River Crossing Project ANNUAL SECTION 5309 NEW STARTS REPORT CAPITAL AND OPERATING FINANCE PLAN September 2011: Adapt Tolling to Different Circumstances if required to Rebalance the Funding Plan

Toll rates can be adjusted within reasonable amounts if additional funding capacity is required. Tolling analyses found that gross toll revenues can be increased by raising toll rates up to almost $6.00 (2006$) each way, after which the diversion impacts of higher rates exceeds the added revenues the higher rates produce. Toll rates that high are not being proposed. However, the analysis demonstrates that an increased toll rate schedule can produce additional funding capacity, if that was required. (Emphasis added; pdf page 43)

Again, adjusting that $6 toll from 2006 dollars to day of opening we get $8.28 each way, or $16.56/round trip, which is $4140 per year for commuters.

Additional comments:

1. The original tolls were for 12 & 8 years, the proposed tolls are 250% to 563% as long at 30-45 years, (or forever if Portland’s METRO gets it way.)

2. The Original tolls were a constant (inflation adjusted) $1.82 & $1.61 while the proposed tolls start at 227% and 256% of the old amounts and increase each year.

City of Vancouver - Tim Leavitt

11. Explain why the CRC LPA decided on light rail transit (LRT) as the preferred high capacity transit

mode instead of bus rapid transit (BRT).  


Clark County - David Madore  

1. How many pages comprise the FEIS. How long would it take the average person to read all of


Comment: This answer is simply incorrect. The FEIS disc includes about 5600 pages of technical reports in addition to the 1400 pages mentioned in the CRC’s response. At 100 pages/day it would take 70 days to read all 7000 pages. That the technical reports are part of the FES is shown by the CRC reference to “FEIS Traffic Technical Report” in their answer to question 7:

The latest data we’ve prepared for southbound peak period traffic is that reported in the FEIS Traffic Technical Report.

5. Does the Federal Government require any transit (beyond buses in mixed traffic) on a

replacement bridge for the I5 crossing?

Comment: Again, this is a simple YES or NO question. Please add YES or NO to whatever lengthy response you desire to give.

6.-9. Relate to:  The latest version of this project eliminates four freeway interchanges and the entire SR-500  interchange for this phase. Call this the LPA2. Provide a map showing the LPA2 components and  the cost of each basic section.

CRC’s entire  answer:

The CRC project has not made changes to the Locally Preferred Alternative. The LPA and the process  to select it was approved by the FTA and FHWA in the Record of Decision in December 2011.  

The FTA:

Significant Changes Since Last Evaluation (November 2011): The project’s capital cost decreased from $3,507.87 million to $2,796.91 million per a local decision to implement the project in phases. The initial phase will include all project elements required to make the LRT, highway, and tolling facility fully functional. Improvements at four highway interchanges, as well as the entire interchange at State Route 500, will be deferred. (WA_Vancouver_Columbia_River_Crossing_Profile_FY14.pdf,  Emphasis added)

Comment: If it is possible to defer some elements of the project such as the interchange improvements as a staging decision, why is it not also possible to also defer light rail as a staging decision?

11. Do the project sponsors retain the authority to stop this project by withdrawing their support or

by objecting to unauthorized changes by the CRC staff

Comment: This is a key question, that the CRC has decided to delay answering. A delay in answering is typically the first step in never answering a question. Especially when the answer will undermine one’s basic claims.

14. Provide the projected costs for the toll collection facilities.

It should be noted that Tampa’s elevated expressway has total toll collection costs of under 10% with a target of 5%. (Source: Lecture by Tampa project’s chief engineer. Video available on request.)

15. Provide the projected costs to collect the tolls (gross verses net revenue).

Comment: CRC’s answer does not appear to contain either of the requested items: projected gross and net toll revenue.

16. What are the costs for each of the major basic components of the project? Each interchange, the

bridge, each parking facility, total light rail costs?

Comment: The CRC answer contains the following:

Deck truss structure that includes the landings for mainline I-5 on both sides of the river. The limits for the landings extend approximately 3,600 feet into Oregon on Hayden Island, and approximately 4,600 feet into Washington in Vancouver.

Is the CRC seriously considering bridge that lands about 500 ft  North of Mill Plain? Shouldn’t the CRC prepare and distribute drawings showing this bridge in perspective over downtown. Especially a scale side view.

Comment: The CRC left out the cost of “each parking facility”?

25. Gross annual O&M cost increases needed for C-Tran to provide extra bus service to serve light rail riders for each forecasted year.

Comment: Please answer the question and only the asked question.

29. Provide the expected real cost per passenger for those C-Tran express buses and for those Light

Rail trains.

Comment: Will the stated cost per ride for light rail match the average trip length of riders from Vancouver to Portland? Does it include all of the same costs as the stated bus such as fare inspectors, police, dispatch, back up buses, and security?

Cost per passenger-mile would be a fairer comparison.

39. What is the projected toll price for commute hours?

Comment: See comments on question 6 (Jim Irish) above.

41. I would ask questions regarding Joe Cortright’s review (attached see pages 1 and 2) of the new

(February 28 2013) CDM Smith Traffic report:

a. Greater than 50% of users will divert to avoid toll

CRC answer (partial):  The February 2013 analysis shows a preliminary estimated decline in traffic of about 25,000 to 50,000 trips a day. ...

Comment: with a reduction of up to 50,000 daily trips, is there any need for this project?

47. Aside from any gains that may be expected or jobs related to project construction, provide the

specifics about job losses as follows:


e. Provide the number of direct construction jobs projected to construct this project by year.

Comment: The question is direct jobs, but the  CRC answer combines direct, indirect & induced jobs. Please supply the requested information.

52. a.) How many of 1 and 2 [questions 49-50] will switch to Vancouver Light Rail?

Comment: Please answer the actual question, (in addition to any clarifications that you feel is needed.)

58. Provide the weekday ridership and frequency projections for this new Vancouver Light Rail line for each year.

Comment: The CRC says that there will be 13,650 daily riders during the opening year, while there are currently only 3300 bus riders and the buses will continue (except the one to the expo center.) This projected 300% increase in ridership raises the queston of where these riders will come from.

62. Table 3-11 of the FEIS Interstate 5 Columbia River Crossing, Transit Technical Report for the Final  Environmental Impact Statement projects average weekday station usage (Ons and Offs) by Mode  

of Access and Egress, Year 2030. Please explain where the following people living/working/study

and compare that to the total population (both current & projected) living/working/studying

within 1/2 mile of the station:

(Question truncated - see original document)

Comment: The answer directs us to “attachment I”, which does not contain the requested data.

Please answer the question with the requested data.

74. TriMet has published weekday ridership and frequency projections for each of their Light Rail

lines, commuter rail, and streetcar projects. They are publishing ridership projections for this

extension into Vancouver. Their track record of credibility and accuracy can easily be established

by comparing those projections as published in the DEIS and FEIS for each of those projects. What

were each of those projections? What are their actual weekday ridership numbers as of the most

recent reports?  

Comments: See Charts on the next page for better perspective on Trimet’s claims

82. Provide the total TriMET ridership by year for the past 10 years for each Light Rail Line.

CRC answer: A chart show [sic] total MAX boardings and boardings by line is attached [Attachment F]. Comment: Attachment F is a graph of total system ridership. The question was for each light rail line, not system totals. Please provide the requested information.

Comment: We note that ridership has declined from about 140,000 in mid 2011 to about 110,000 by Feb 2013.  Did you model predict this? If not, what is the implication for other predictions of that same model?

Attachment 3 of the May 21, 2013 C-Tran agenda contains additional answers to Mr. Madore:

The complete question 4 and answer:

4) What are C-Tran's plans to pay for the LRT costs if the projected revenue is not

realized? E.g. what will the impacts to regular bus service be?

In general terms, should revenue shortfalls materialize for CRC LRT in

Vancouver, C-TRAN could consider a number of options, as it has in the past with

its core bus service. Examples of some of those options include:

a. Consider fare increases;

b. Consider charging (or charging more) for the LRT park and rides;

c. Consider non-service related administrative costs;

d. Consider reducing CRC LRT frequency;

e. Consider reducing other services.

It is impossible to say what the impacts to regular bus service could be given the

options available and ultimately, any decision would be made by the C-TRAN Board

of Directors

Comment: In other word: Cutting bus service is “on the table.”

PDF of this page

CRC’s answer to C-Tran   Comments on CRC’s answer   Trimet’s projections accuracy   Correcting false claims about the CRC