Steve Cunningham
Department of Metropolitan Development
6th Floor
129 E. Market St.
Indianapolis, Indiana 46204

Dear Mr. Cunningham:

Thank you for the copy of the Comprehensive Rail Study. I found it most informative and well done. I do, however, have several comments on the study. I realize that the study is probably in final form, but thought I would offer my input anyway in the event any future revisions or follow-ups are planned. Several of these comments are in the form of questions that were not answered by the study, but I do not expect you or anyone else to respond to them. They are simply for feedback purposes. Doubtless some of these points were addressed in technical documentation that was not part of the final report.

My comments can be divided into three categories: inconsistencies, potential inaccuracies, and areas for clarification; areas of disagreement; and scope issues. They are detailed below. Please feel free to share these comments with the study team or anyone else you feel might be interested.

Inconsistencies, Potential Inaccuracies and Areas for Clarification:

1). On page 19, the Conrail Flexi-Flo Bulk Transfer Terminal is sited at Hawthorn Yard. This is also implied on page 21, which also locates the Hawthorn Yard at Sherman Dr. and Southeastern Ave. However, page A-17 lists the Flexi-Flo Terminal as being located at the Avon Yard. Either there are multiple facilities or one of the listings is incorrect.

2). In prioritizing the preservation of rail corridors, it was never explicitly stated what criteria were used in setting the priority. In various places it is implied that the preservation priority is for transit/recreational use (as opposed to freight service). However, this does not always seem the case. For example, the Indiana Rail Road is considered a high priority for preservation even though it has acknowledged problems as a transit/recreational corridor (p. 64).

3). It was stated that any transit service on the CSX Indianapolis line to Cincinnati would require utilizing trackage rights over Conrail to Union Station and that sufficient rights probably existed (p. 64). However, it did not state whether trackage rights on other rail lines (e.g., the Louisville and Indiana line) were sufficient for passenger rail access to Union Station.

4). On page A-10, the Conrail Louisville Secondary is shown as having no signal system. However, I have recently crossed what I believe to be this line (at a grade crossing on Terrace Ave just west of Madison Ave) and saw what appeared to be an active rail signal for southbound traffic showing yellow.

5). Segment 20 (the northwest belt tracks) was listed as having a low to medium potential for abandonment or sale (p. A20). However, on page A-3, it is stated that provisions of the belt agreement make it unlikely any segment of the belt will be abandoned. Does that agreement apply to segment 20? If so, how can that segment have a medium potential for abandonment when segment 3 (which has no customers, per page A-3) has a low potential?

6). My understanding is that originally the tracks which comprise the Conrail mainline through downtown were built to allow shared access for all railroads to Union Station. Are there any residual trackage rights that may have been part of the original agreements for use of those tracks which might allow commuter trains access to Union Station? This could be useful in the event Conrail is unwilling to allow commuter train use of its tracks. (Page 64 says that Conrail states commuter rail service is precluded on its mainline tracks).

Areas of Disagreement and Miscellaneous Points:

7). On page A-15, the preservation priority of the Conrail Kraft Running Track is listed as low, despite a preservation priority of high given to the Conrail Crawfordsville Branch which parallels it (p. A-16). If this Conrail route from downtown west to the airport and beyond is to effectively serve as a passenger rail corridor (either commuter or light rail) in the future, then both tracks need to be preserved. Having only one track precludes simultaneous bi-directional service. This would make it almost impossible to implement light rail and difficult to implement commuter rail. The examples of other cities would confirm this. For example, in Chicago, all Metra commuter trains, all Chicago Transit Authority heavy rail trains, and the Chicago South Shore and South Bend Railroad light rail service all utilize corridors which have at least double trackage. There is only one route that is single tracked. That is the future Metra Wisconsin Central commuter service, which will feature only inbound trains in the morning and only outbound trains in the afternoon.

8). On page 65, the potential costs of establishing a commuter rail service are listed as $30 to $40 million per corridor. I believe that these costs may be substantially underestimated. For example, on the aforementioned Metra Wisconsin Central line, the cost of establishing service will be approximately $100 million. (I do not have an exact citation for this, but the figure has been widely quoted in area newspapers). This figure is for an area where a commuter rail infrastructure (such as downtown terminal facilities, ticketing systems, and administrative services) are already in place. The Wisconsin Central rail line itself was also in reasonably good shape. (This is an inference based on the fact that I regularly drive roads that intersect that line. No major track overhauls have occurred in the previous two years and commuter rail service is scheduled to start this summer). Various newspaper accounts (sorry, no exact citations, but I am sure they could be located if required) examining future potential corridors have listed costs per line in excess of $300 million. I would recommend examining the Metra Wisconsin Central experience during any study of the feasibility of commuter rail in Indianapolis.

9). The light rail study mentioned (pp. 49-50) examined a four quadrant light rail system which was considered not to be cost effective because it only increased transit boardings by 17,000 despite a cost of $683 million. This study may be misleading since the cost of constructing light rail and the benefits achieved may have been substantially different on each quadrant. Additionally, a commuter rail option was not examined. A study of the feasibility of a single line commuter rail service (for example, the former Norfolk and Western line) may have yielded substantially different results. The $100 million Metra Wisconsin Central line mentioned above was considered cost effective even though it will carry only an estimated 5,400 passengers per day. (That passenger figure is again from newspaper accounts I have read but cannot cite. Unlike with the other figures mentioned, I cannot be certain that this is the exact value. However, it is in the ballpark).

10). Segment 4 (the Belt-Conrail mainline connector) and Segment 23 (the Belt itself) were listed as low priority for preservation (pp., A-4, A-23). However, the belt track and connector could be used as an alternate routing for the numerous through trains running through downtown. If Conrail could be convinced to run all of its freight trains on a rehabilitated, dual track belt line, the problem with 15 MPH freight trains blocking access to Union Station would be eliminated. This scenario may seem unlikely, but if the rehabilitation of the belt tracks were federally funded as part of a commuter rail project, it might be much more appealing. I would have listed the preservation priority of these segments to at least medium in light of this scenario.

11) One potential passenger rail route that was not mentioned was a possible Bloomingtion to Indianapolis International Airport (or downtown) route along the Indiana Southern tracks. The 1996 Indiana Department of Transportation (INDOT) state highway map shows a rail line leading from the Indiana Southern tracks at Gosport to Bloomington. My assumption is that this is not abandoned. This route might provide weekend transportation for students to the airport as well as connect with a future light rail route from the airport to downtown, thus providing a Bloomington to downtown transit route, or use Conrail trackage to downtown.

Scope Issues

12). The study only examined currently active rail routes. It did not determine whether there were any already abandoned routes that might be suitable for recreational, transit or freight unless those lines were already under development. For example, the abandoned rail line extending from the Conrail Crawfordsville Branch west to Plainfield and beyond (I think this is the route) might be used as both a transit line serving Plainfield and the proposed amusement park at I-70 and SR 39 as well as a freight line serving the new industrial areas west of the airport.

13). While the study mentioned that abandonment of rail lines is often precipitated by a required rehabilitation of a major structure such as a bridge, it did not catalog such structures and their current conditions. If any major structures are in need of imminent replacement, this would be vital information to have. Additionally, an inventory of rail bridges and other major structures would be useful reference information.

14). Another area that was apparently not within the scope of the project was an assessment of railroad grade crossings. Grade crossings were obtained from Department of Capital Asset Management files, but no attempt was made to determine which grade crossings required improvement. A prioritized list of potential grade separation projects, and a separate list of grade crossings where additional signals/gates are required could have proven very valuable as input into highway planning. There are several busy rail lines in Indianapolis with poor grade crossing protection. For example, while the CSX Indianapolis to Cincinnati line has 3-8 trains per day (p. 25), there are no gates at the Post Rd grade crossing and other grade crossings on this line lack even warning flashers. (These statements are based on recent personal observations).

15). Information on the relationship of the Indianapolis rail network to the statewide network would have helped add perspective. More information on the relationship of Indianapolis rail lines to the Conrail and CSX national networks would also have been helpful.

16). Information detailing the role of the city and INDOT in the rail planning process and the relationship between the two entities would have added value to the study. I believe INDOT has published a State Rail Plan. An assessment of the current rail conditions in relation to this plan would also have added value.

17). Another item which would have added perspective to the plan is a comparison of the Indianapolis network in relation to rail networks in similar cities. Examples would be Cincinnati, Louisville, and Columbus, Ohio.

Again, let me say thank you for the copy of the study. I have found your office to be very helpful with all of my inquiries. Having spent the past couple of years in Chicago, it is a pleasure to deal with public officials who are interested in dealing with the public! I hope you had an enjoyable holiday and keep up the good work.

Sincerely,