Edward Stewart Wright
Littleton, Colorado 80123


April 9, 2001

Mr. Tim Tetherow, Project Manager
I-70 Mountain PEIS
J.F. Sato and Associates
5898 South Rapp St.
Littleton, CO 80120

Mr. Brian Pinkerton
Region 1, CDOT
4201 E. Arkansas Ave.
Denver, CO 80222

Mr. Mark Walbrun, Vice President
TransSystem Corp.
1050 Perimeter Dr., Suite 1025
Schaumberg, IL 60173

Gentlemen:

It was a pleasure to meet you and I appreciate your discussing aspects of the PEIS with me. Also, thank you for providing the opportunity for public comment on the status of the PEIS as presented on April 4th and l7th. The studies to date are well thought out and properly executed. In particular, it is gratifying to see (at last!) feasibility studies being performed on various alternatives for the I-70 mountain corridor, as I strongly urged in my book, SMARTrans.

The following comments are preliminary since I have not had time to analyze the voluminous data. All comments are to be considered as constructive and as an aid to your complex selection process. Please give them careful consideration.

COST

The most serious deficiency of the study is the neglect of cost as the single most important screening factor.

The reason that cost is so important to this project is because the voters of our small state must specifically approve the expenditures to implement any alternative system. This situation is entirely different from the more typical situation studied by CDOT, where the state has a constant stream of funding, needs only standard construction methods (for interchanges or widening for example) and cost becomes the primary factor only as bidders are evaluated. The lack of cost consideration was a major defect in the previous CDOT study (the MIS) and it must be emphasized in the PEIS. The cost should be divided in two parts, one for construction and one part for the research, development and demonstration (RD and D) (if necessary) to guarantee the level of reliability satisfactory to the success of the project.

My suggestion, a Swiss-type meter-gauge railway, was conceived primarily because it is the lowest cost of any proposed non-highway system. Your analysis does not reflect the major cost savings made possible by its light rail, tight curve and cog/rack characteristics. When you specify a common alignment for light rail, heavy rail, standard-gauge and meter-gauge, it is quite obvious that any advantage for SMARTrans will be marginal, when in fact its implementation cost would probably be 30% lower than standard-gauge heavy rail. This advantage amounts to hundreds of millions of dollars and could well be the difference between voter approval and rejection.

The other key aspect is RD and D cost. Rail does not require an RD and D investment since it is based on proven technology in daily commercial use throughout the world at (or better than) the projected speeds. The CIFGA monorail, on the other hand, does not exist. Nor has it even been designed. None of its key components have even been tested. Its proponents have declined to invest in proof of concept testing, even though such action might have been sufficient to pass HB 98-1335 last year. While no one can predict the exact amounts required to develop a high-speed monorail, it is clear that hundreds of millions of dollars would be required. Since neither the developer or the federal government is inclined to make these investments, this burden could fall primarily on the Colorado taxpayer.

I do not know what figure of merit you will use to compare implementation cost. I suggest that you use the Colorado taxpayer's cost per passenger over the next 20 years. Big numbers by themselves are meaningless to the average voter and this suggested figure of merit is easily understood. For example, either the meter or standard-gauge railway could be completed within 3 years of voter approval. If we assume that 6 million passengers annually are carried, averaged over the following 17 years, either system would carry 100 million passengers during the 20-year span. If the meter-gauge costs $1 billion to implement and the standard-gauge $1.3 billion and that the Colorado taxpayers provide 25% of the total (as suggested in my book), the meter-gauge costs $2.50 per passenger and the standard-Gauge $3.30 per passenger. The monorail could not be implemented for at least 6 years after voter approval, including the necessary time for RD and D. If the monorail cost as little as CIFGA's estimate of around $4 billion (very unlikely in my opinion) and we add an estimate for monorail RD and D cost of $1 billion, Colorado's 25% share of the cost to carry 84 million passengers (14 operating years at 6 million passengers per year) is almost $15 per passenger carried. These figures are understandable, represent the voter's commitment and clearly illustrate the differences between competing modes.

On another aspect of cost, I understand that you are relying on the Colorado School of Mines for tunneling cost data. Your figure of $35 million per mile for a tunnel through the notoriously difficult hard, fractured rock at the continental divide seems very optimistic. While I understand that shaped charged fracturing could reduce current costs, I would caution you that School of Mines is also the source of much of the pro-monorail analysis which has fired the enthusiasm for CIFGA's monorail. And since the monorail must have a tunnel, please treat their numbers skeptically and verify them with at least one separate outside source.

My tunneling estimates for the two miles to pierce the continental divide at $70 million per mile plus the mile at Silver Plume yield a total of around $200 million. In contrast, SMARTrans requires no tunnels and approximately three miles of cog/rack track to surmount Loveland Pass for a comparable total of around $60 million dollars. And, although your study does not include Grand County, surely there must be consideration that eventually a similar comparison could take place at Berthoud Pass.

Please understand that I would not rule out a tunnel for SMARTrans, but is a 10-minute cost saving that critical? I believe it is more important to gain voter approval with the minimum-cost approach and save tunnel, capacity and alignment improvements for future years once the system has proven its usefulness.

RISK

The second most serious problem with the study is its omission of risk analysis. Again, risk is not an important factor in most CDOT evaluations. In this case it is absolutely critical that risk analysis be a major selection factor. In performing business assessments of technology-based multimillion dollar projects for over 40 years for both Fortune 100 and smaller companies, I cannot recall a single case in which risk analysis was not critical. The risks here fall in two categories, both highly important. The first is the technological risk. If substantial investments were being made in the monorail on a continuing basis, this risk would be expected to decline with time (or at least become better defined). Since this is not the case, the technological risk of that concept is simply unacceptable. Both meter- and standard-gauge rail pose negligible technological risk, but the concept of a long-distance electrically powered rubber-tired captive hybrid bus system entails substantial risk. No long-distance, high-speed hybrid bus system is in commercial operation, nor to my knowledge has one even been tested.

The second risk factor is financial. Highway improvements have negligible financial risk because the costs are well-established and the funding sources essentially identified. Rail and hybrid bus are somewhat higher primarily because the funding is not identified. There should also be serious concern whether a bus system would attract enough riders. The financial risk for the monorail is substantially higher not only because of its inherently expensive characteristics but because of its undefined RD and D and implementation costs.

ENVIRONMENT

A properly designed meter-gauge light rail system would be expected to have the least environmental impact. Less material needs to be removed, there is more flexibility in snaking the right-of-way through critical areas (a 10-ft. ROW should be specified in certain critical areas such as Idaho Springs and Silver Plume), and its energy consumption is the least of any candidate.

I honestly don't know how to quantify the visual aspects, but the single-track meter-gauge is aesthetically pleasing, as my book shows it is in Switzerland. A double-track railway would be less so, and I personally find the monorail to be visually appalling in our beautiful mountain environment. I also note that many of my readers enthusiastically endorse the views possible from the Loveland Pass traverse on the meter-gbauge cog section. On the other hand, tunnel transit is boring, as anyone who has ridden through the Chunnel or ridden on the bullet train extension to Hiroshima can attest.

GENERAL

It is critical that this current study be credible and definitive, particularly in view of the failure of the previous CDOT corridor MIS (see Chapter 14 of my book for a summary of how the 1998 MIS is fatally flawed).

My choice of systems for further study in the PEIS are as follows:

1/Single-track, meter-gauge light rail with approximately 3 miles of cog/rack at Loveland Pass
2/Double-track, standard-gauge heavy rail with single-track tunnels
3/Double-track, CIFGA monorail with single-track tunnels
In full recognition of all of the above factors, I urge you to continue consideration of a meter-gauge cog/rail system similar to that described in my book. It does not make sense to eliminate the lowest cost, most environmentally sound concept from the state's official environmental impact study of this critical corridor.

Sincerely,



Edward Stewart Wright





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