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Regional Rail Working Group
New Jersey Association of Railroad Passengers August 4, 2004
Mr. Anthony G. Cracchiolo, Director, Priority Capital Programs Dear Mr. Cracchiolo, We are in receipt of your letter of June 10th, 2004 detailing your agency's evaluation of NJ-ARP's proposal dealing with the "Connection of PATH to New York City's Lexington Avenue Subway." We would request that the following response be entered into the formal NEPA record of the Draft Environmental Impact Statement (DEIS) concerning the reconstruction of the permanent PATH Terminal at the World Trade Center (WTC) site in lower Manhattan. We thank you and your associates for the time and effort involved in evaluating our series of proposals but feel that certain aspects of them were misunderstood and misinterpreted by both the PANYNJ, and your consultant, Parsons, Brinckerhoff, Quade & Douglas, Inc. (Parsons Brinckerhoff) whom you retained to examine the multiple facets of the design, constructability, operation and maintenance and federal regulations of the PATH/Lex Connection. In turn, adoption of, and strict adherence to, New York City Transit's (NYCT) best practices for grades, curvature and intersecting line separation distances as put forth in the "MW-1 Track Standards and Reference Manual" virtually precludes not only the PATH/Lex Connection but also most future subway or regional rail construction both in lower Manhattan and, in fact, much of the rest of Borough. Norm Silverman, New York City Transit Director of Operations Planning, stated at our March 26, 2004 meeting that exceptions from these standards were possible as long as the deviations were not extreme. That we adhered to current practices should be proof that the PATH/Lex Connection was conceived within operational constraints. NJ-ARP, and subsequently the "Regional Rail Working Group," (RRWG) was hopeful that a frequent and truly interactive process between your agency, the consultants and our group could have materialized in order to refine the PATH/Lex Connection over its almost 15 month gestation period. Unfortunately, this did not occur. If it had, certain technical elements of the plan could have been discarded and that would have led to more fruitful discussions between all parties saving everyone considerable time and effort. To cite one specific example, Parsons Brinckerhoff presented in their December 11, 2003 Figure 3 a gradient of 10.8% when referring to NJ-ARP "Alignment 2.1." That Parsons Brinckerhoff would even propose a further "Alternative Alignment to NJARP Proposal," dated December 4, 2003, that employed a 15.9% grade and that it would be offered by the PANYNJ neither enhanced the credibility of our cause nor contributed to an effective on-going dialogue on the proposal. Clearly, grades of this kind are operationally impossible in service. They were never proposed by NJ-ARP and should never have been attributed to the advocacy groups. So it should come as no surprise to you that NJ-ARP and the RRWG are profoundly dismayed and disappointed with your statement to "...not plan any further investigation of the proposed connection at this time." NJ-ARP and the RRWG would like to address several of your comments regarding concept, alignment selection, station placement, vehicle compatibility and operational criteria and funding. Concept The original concept of the PATH/Lex Connection emerged from wide ranging discussions in the aftermath of the unprecedented terrorist attack on the World Trade Center on September 11, 2001. For over 10 years, the PANYNJ has been the lead agency on the "Access to the Region's Core" (ARC) study whose initial goal was to tie the tri-state metropolitan region together through the expansion of the existing regional rail network by adding capacity enhancements at several key choke points. Among them, this included the addition of two trans-Hudson rail tracks and, in one option, the connection between New York Penn Station (NYP) with Grand Central Terminal (GCT) with a physical track linkage. A key consideration in the latter, as explained in the scoping document for the initiation of this study, was the critical determination that about 70% of all midtown Manhattan job sites are within a short walk of GCT. The importance of east midtown has been accentuated as many employers relocated their facilities in the wake of the terrorist attack. But with the lack of any substantive relief from the ARC project expected in the near term -- implementation is years, if not decades, in the future -- NJ-ARP concluded that many of the anticipated benefits to be provided by ARC, principally access to midtown Manhattan, could be achieved relatively quickly (within three to four years) and inexpensively ($800 million to $1 billion) by the PATH/Lex Connection given the forthcoming reconstruction efforts at the WTC site. Alignment and Constructability With that in mind, and after our initial meeting with the PANYNJ on March 31, 2003 and subsequently with the PANYNJ and the MTA/NYCT on March 26, 2004, NJ-ARP, joined by the RRWG, refined its alignment in several iterations to comply with best practice operating parameters of the existing PATH and NYCT properties. The PATH/Lex Connection is premised on grades of 4.5%, curve radii of 200 feet and a minimum rail to rail clearance of 17 feet (where the connecting track passes under the "A" and "C" subway line) and 14 feet (where the track link passes over the "#2" and "#3" line at Beekman Street). We do agree that the paramount issue is the feasibility of building these close clearance intersections without infringing on the reliability of these heavily traveled lower Manhattan transportation arteries. However, we do not agree with your observation that "...we were unable to identify a feasible vertical alignment that can be constructed to avoid all of the PATH and subway lines and meet in the Brooklyn Bridge Station..." and therefore reject "...the variation offered in your April 23rd letter as a workable solution." We would be disingenuous if we didn't remind the PANYNJ, NYCT and Parsons Brinckerhoff that the NYCT's much praised #7 line operates on two minute headways and surmounts 4.5% grades in its Steinway Tunnels located to the west of Grand Central Terminal and in Long Island City. Even steeper gradients can be found on the approaches to the East River Bridges. The PATH has used 115 foot radius curves on its WTC approach and departure tracks for 30 years while NYCT has turned trains on its 147 foot radius City Hall loop for a century, both with no ill effect on operational reliability. Because of the age of the structures in this part of the City (some dating back to Colonial times) and the narrow street grid, engineering of the City's early subway infrastructure was carefully built to preclude damage to any number of priceless historic structures. And if success can be gauged by the yardstick of longevity and uninterrupted service, these lines have served the City faithfully for almost a century and likely will continue to do so for at least several more. And so the fundamental question remains "Why change the rules of the game when the current ones are perfectly adequate." Or in the vernacular, "If it ain't broke, don't fix it." And yet that is exactly what NYCT has done. NJ-ARP and RRWG revised its plan and submitted "Alignment 2.8" to you on April 23rd to be in accordance with physical constraints of the existing PATH and NYCT infrastructure. Yet Parsons Brinckerhoff suggests that 230 foot curve radii result in track that impinges on the footprint of One WTC, interferes with the temporary PATH Station and has grades in excess of 6%. In fact, this alignment employs 200 foot radii curves, avoids the footprints of both WTC towers (something the present "temporary" station fails to achieve), passes over the tracks and platforms of the temporary station (albeit taking some of the northern part of the concourse) and has grades of no more than 4.5%, all this within existing NYCT practices. If the only reason that can be found to reject further discussion of this alternative is to invoke more restrictive clearance distances, grades and curving standards, then it is a grim portent, indeed, for future Manhattan mobility options. We know that constructability will be challenging; but it is not impossible. Ways were devised during the building of the WTC to keep PATH running and we have no doubt the creativity of the PANYNJ and MTA/NYCT engineers and designers will rise to the occasion, if only those agencies would be afforded the opportunity to do so. While this alternative would sever the southbound City Hall Lexington Avenue #6 loop track, this interruption in service would only occur after all other work is finalized. Certainly, the 63rd Street tunnel local-express connection was built under the heavy load experienced by the Queens Boulevard four track subway line and underpinning of lines in service is not unknown during subway construction and station alterations. As NJ-ARP and the RRWG listened to the comments of PATH and NYCT concerning operational constraints of an integrated system -- at least in the near future -- we devised "Alternative 4.2" that features a cross platform transfer between the #6 Lexington Avenue local (which is extended from its Brooklyn Bridge terminal to the WTC site) and the PATH. The separation between the two transit systems is maintained and the City Hall loop severed and taken out of service with the #6 subway trains reversal now taking place at the WTC site. If and when operational, jurisdictional and equipment issues can be harmonized, through running could still be adopted. This alignment stays within the bathtub on the west to avoid expensive, wet construction in West Street and to make continued operation of the temporary PATH station easier but does extend south of the bathtub to achieve less restrictive curve radii. Station Placement The Parsons Brinckerhoff analysis suggests that the proposed station location for the NJ-ARP "Alignment 2.1" "...would be located on the 4.0% grade. This exceeds the NYCT criteria of 0.5% maximum grade for new station construction. Also the switches within the interlockings would be placed on grades exceeding the 1.5% maximum allowable grade, and would be located within vertical curves." NJ-ARP spent considerable time with industry professionals and examined closely appropriate track diagrams to assure that the revised station location in "Alignment 2.8" which is oriented in a northeasterly direction is, in fact, on a gradient of 0.5% and meets NYCT criteria. Comprised of a basic two track, side platform facility, it is close to, and formally aligned with, the proposed station entrance just south of Fulton Street. A close examination by Parsons Brinckerhoff of the vertical cross section of "Alignment 2.8" should have revealed that the top of rail clearance between the tracks of the temporary station and those of the tracks leading to the WTC PATH/Lex station is 14 feet, perfectly adequate to allow the temporary facility to continue operations during construction of the new link. The grade never exceeds 4.5%, this in direct contrast to Parsons Brinckerhoff's assertion that it contains a "...track grade in excess of 6% to avoid the A/C, N/R, and 4/5 subway lines." NJ-ARP and the RRWG never suggested that a tunnel boring machine be used for station or right-of-way construction; rather, the openness of the "pit" pointed to a reduced cost of building in that nearby "soft ground." Underpinning is a typical facet of underground development, whether for subways, water, sewer or utility lines. Vehicle Compatibility and Operational Criteria We examined the dimensional differences between the IRT and PATH vehicles and have concluded that while width, length and truck center variations are evident, there is no technical barrier preventing the design of a hybrid vehicle to allow operation on both transit systems. In fact, the PANYNJ had considered an add on order to the NYCT's R-142 purchase according to an article in the Newark Star-Ledger. That PATH has announced an order to replace much, if not all, of its aging fleet was a principal reason in crafting the PATH/Lex proposal after the terror attack on 9/11. Through operation between the PATH and Lexington Avenue subway using 10-car trainsets need not necessitate lengthening "...all PATH platforms..." The Draft Environmental Impact Statement (DEIS) states that "...PATH plans to implement 10-car service on its Newark-WTC line..." but this action "...is not planned at this time." Still, Newark, Journal Square, Exchange Place and the WTC stations are already capable of accommodating 10-car PATH trainsets. Only Harrison and Grove Street have not been enlarged but could still accommodate 10-car sets although certain ones would not open their doors at that location. The Hoboken line does present a challenge, which, while not insuperable, would initially restrict through running to only the Newark line. As to car widths, given that PATH vehicles are 8.75 inches wider than IRT cars, the width of the PATH fleet replacement purchase would be reduced accordingly, resulting in a 4.375 inch narrower profile on the platform side with PATH platforms reduced in a like amount. No interior passenger room need be lost since the exterior of the car can turn in more sharply at platform level than at present. Recall that "Alignment 4.2" was presented to you to circumvent this difficulty and permit the continuation of separate non-integrated PATH/NYCT system operation with variable PATH train lengths until that time when all operational, jurisdictional and vehicle compatibility issues could be overcome. Funding One of the inevitable questions that was raised in the evolution of the PATH/Lex proposal is where the money would originate for its construction. Presently, the cost for the permanent WTC station ranges between $1.7 billion and $2.0 billion with the PANYNJ requesting $1.4 billion to $1.7 billion from FEMA/FTA. Our estimate for the 3000 feet of track to link the downtown PATH tunnels to the #6 Lexington Avenue local line at Brooklyn Bridge Station is about $800 million to $1 billion, using the 8 mile, $16 billion Second Avenue subway expense as a guide. No official thought that any remaining federal monies were left over to be directed to PATH/Lex. Yet, late in July, the Bush Administration, subject to Congressional approval, agreed to pay New York some $2 billion in additional transportation money in a swap for unused tax credits that were part of a $20 billion 9/11 aid package. The White House agreed that the City could redirect the Liberty Zone tax benefits into transportation related projects. The project that will be the recipient of these funds is a direct track link to New York City's JFK Airport with a new tunnel under the East River. Yet, with a short 1.5 mile extension of the PATH to Newark Liberty International Airport (EWR) from Newark Penn Station (ignoring for the moment the NEC airport monorail interface which provides two stop service to New York Penn Station) at a fraction of the JFK $6 billion cost, travelers would be able to access lower Manhattan on an existing PATH rail line that has experienced a 50% decline in ridership from that which existed on 9/10/01. And if the PATH/Lex Connection was built, this direct airport access would extend to the entire east side of Manhattan as well. To us, this sounds like a far better transit investment than a $6 billion tunnel under the East River to bring, at most, several thousand airline riders a day into downtown Manhattan. NJ-ARP and the RRWG remain committed to a continuing constructive dialogue with the PANYNJ and NYCT regarding the PATH/Lex Connection even though your letter claims that the two agencies "...do not plan any further investigation of the proposed connection at this time." This opportunity is finite and eventually will no longer be available to merit consideration. Our concern remains that if this PATH/Lex proposal is not addressed in an expeditious manner, the opportunity will be lost for generations. Yet if all stake holders can put aside their own individual jurisdictional and institutional imperatives, this transportation link can be implemented and held out as a positive accomplishment in the wake of one of the most tragic episodes in American history. Sincerely,
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