Re: Docket B16-03, Proposed changes to Metrorail operating hours

WMATA has two big issues right now, their proposal to cut service hours ("Plans for Metrorail contraction in the face of London Night Tube expansion") and dealing with next year's budget deficit ("Can WMATA's death spiral be staunched?").

Docket B16-03: concerns the former. Written comments were due yesterday. This is what I submitted. The addition to the text below is only the different proposed options. I was motivated to post these comments in response to the GGW post, "Prince George's County leaders join the chorus to keep late night rail service" (in part because of Alex B's comment, which dovetails the argument in points #1 and #2).

I decided not to submit voluminous comments.

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For the most part I am not supportive of the Metrorail proposals for significant cutback in service hours, which have been offered in response to an identified need for more time for maintenance.

First, irrespective of the current SafeTrack program, WMATA has not provided a convincing argument for why it needs significantly more time to conduct maintenance operations when compared to peer transit systems.

For example, the MBTA system runs from about 5:15am to just after midnight on weekdays, til 1 am on Saturdays, and from about 6:15am to just after midnight on Sundays. The TTC runs from about 6am to 1:30am Monday through Saturday, but with an 8am start on Sundays. The CTA provides 24-hour subway service on the Blue Line and about 21 hours of service daily on the other lines, with a start between 4am and 5am on most lines, with a slightly later start on Sundays.

Ironically, WMATA's proposal for service hour cutbacks is occurring at the same time that London is going to 24 hour weekend service on a number of its Tube Lines.

Second, relatedly and furthermore, various inspection reports from FTA indicate that the Metrorail system is extremely inefficient and suboptimal in terms of scheduling and performing maintenance work. Rather than penalize riders for the system's operational inefficiencies, Metrorail should focus attention on better use of maintenance resources and use the time that is currently provided in the schedule for revenue service.

Before WMATA takes the action of cutting back on service, instead this question should be asked and answered:

What is it about WMATA Metrorail operations that makes it unable to perform adequate maintenance in the same amount of time by comparison to peer systems?

If it is the case that objectively Metrorail needs more time for maintenance, then it would be reasonable to consider the current proposals. But so far, Metrorail/WMATA have not adequately made the case, only that the number of hours available for maintenance has been reduced (from 44 to 33) since the adoption of late night service hours on weekends.

Third, regarding the specific proposals, #1 is closest to adequate except that it includes as permanent the dialing back of later service on Fridays and Saturdays. However, the proposed Sunday closing time of 10pm is deleterious and should remain at the current time of approximately midnight.

Previous late hours Metrorail service profile

Mon-Thu: 5:00 a.m. - midnight
Fri: 5:00 a.m. - 3:00 a.m.
Sat: 7:00 a.m. - 3:00 a.m.
Sun: 7:00 a.m. - midnight

WMATA has put forward four different options for reductions in service:

Proposal # 1
Mon-Thu: 5:00 a.m. - midnight
Fri: 5:00 a.m. - midnight
Sat: 7:00 a.m. - midnight
Sun: 7:00 a.m. - 10:00 p.m.

#1 -- good/adequate in that service goes to at least midnight, Monday through Saturday, but bad in that Sunday service is proposed to end at 10pm.

Proposal # 2
Mon-Thu: 5:00 a.m. - 11:30 p.m.
Fri: 5:00 a.m. - midnight
Sat: 7:00 a.m. - midnight
Sun: 7:00 a.m. - 11:30 p.m.

#2 -- is bad because it proposes ending Mon-Thursday and Sunday service before midnight.

Proposal # 3
Mon-Thu: 5:00 a.m. - 11:30 p.m.
Fri: 5:00 a.m. - 1:00 a.m.
Sat: 7:00 a.m. - 1:00 a.m.
Sun: 8:00 a.m. - 11:00 p.m.

#3 -- is better than adequate because it proposes ending Friday and Saturday night service at 1am, but it fails in that it proposes a one hour later start and a one hour earlier closure for Sundays.

Proposal # 4
Mon-Thu: 5:00 a.m. - midnight
Fri: 5:00 a.m. - 3:00 a.m.
Sat: 9:00 a.m. - 3:00 a.m.
Sun: Noon - 11:00 p.m.


#4 -- would be the best proposal if it didn't provide for significantly later start for weekend service, at 9am on Saturday, and noon on Sunday. However the proposal for service til 3am on Friday and Saturday is laudable. But it is also a negative that it is proposed to cut Sunday service to 11pm.

Fourth, the service schedules as proposed seem to indicate that WMATA/Metrorail is choosing to abdicate transit service vision in terms of providing the means for residents to adopt a sustainable mobility lifestyle with a foundation of high quality transit service throughout the day, complemented by walking, bicycling, bike sharing, car sharing, and delivery services.

Instead, the organization is focusing primarily on its role as a commuter transit service on weekdays.

The competitive advantage of Washington, DC specifically and the Washington Metropolitan area more generally as a place to live and to locate and conduct commerce and government activities is based on a rich transit infrastructure that allows for efficient conduct of trips that are time and cost effective.

This competitive advantage presupposes a transit service that provides frequent service for much of the day, comparable to systems in NYC and Chicago. Instead, the headways between Metrorail trains have significantly degraded, especially in the evenings and are to the point of deplorability on weekends.

In fact, because of the significant decline in frequency of service as well as various unplanned service interruptions, in this particular household, Metrorail is no longer our first choice for non-work trips. Instead, we choose one way car sharing as a matter of course, especially because the cost of a trip is equal or cheaper to the cost of two Metrorail fares WRT transit service during the week, my wife tends to prefer bus over Metrorail because of higher reliability, while I choose to cycle.

Fifth, related to point one that "WMATA has not provided a convincing argument for why it needs significantly more time to conduct maintenance operations when compared to peer transit systems," Metrorail's service quality degradation has long since destroyed the trust that once existed between the agency and riders in terms of faith in the system to operate well and with rider interests in mind.

The frequent service breakdowns, structural failures (e.g., the fire at L'Enfant Plaza which killed a rider, not just because of equipment failures but failures by Metro personnel including the Transit Police and the Rail Operations Center) and inadequate explanations by Metrorail personnel have cut the bind that once tied riders and operators together.

Since 2009 and the Fort Totten crash which killed nine people I have suggested* that it is necessary for WMATA to rebuild the metropolitan/regional consensus about the value of the transit system and its context WMATA also had this opportunity this year, on the occasion fo the 40th anniversary of the start of Metrorail service, but it has not done so.

Now that the inadequacies of WMATA's current system of finance have been laid bare in the face of increased financial demands for maintenance tied with other cost increases and a decline in fare revenue across the board, WMATA is finding it difficult to raise additional funds from the jurisdictions. Were the regional consensus rebuilt, WMATA would find that the necessity of changing the funding structure would be better understood and there would be greater support on the part of elected officials and residents for doing so.

(It could be argued that the Metro Forward process was an attempt to reconstruct the regional consensus was such an attempt, but I disagree because the proposals were satisficed significantly to ensure suburban support, and a path forward on new financing was not proposed.)

* See attached

Sixth, the discussions of cutting back late night service indicates the more general failure of WMATA to not have planned for a 24-hour transit network anyway in terms of providing network breadth, depth, and redundancy.

In the face of the proposed cutback on the hours of Metrorail service, the indicator of interest in creating a more formal night network as presented in the related planning documents is a step in the right direction but it is not a full blown proposal,

It appears to be inadequate to the overall need generally and in the face of the proposed cutbacks. Furthermore, the planning documents do not offer a commitment on the part of WMATA to undertake such service, only an indication to explore the need.

While the reality is that the TPB should be the primary and lead transit planner for metropolitan transit needs that is not the case in practice, and by default WMATA is that planning agency.

With regard to late night transit service, cities such as Chicago, San Francisco, and Toronto have long offered extensive night transit networks comprised of bus and/or streetcar service, either in addition to or as a substitute for heavy rail service.

In the present day, currently the San Francisco Bay region is working to better provide and coordinate late night service across jurisdictions, to the point where they have constructed an integrated transit map for late night service. This would be a better model for WMATA and riders than what has been currently offered.

The SF late night transit map is offered as Attachment 2 (posted here instead).


ATTACHMENT 1

From "St. Louis regional transit planning initiative as a model for WMATA," November 2009.

The DC region needs to embark on a wide ranging metropolitan transit (re)planning public process to restore trust in and a common understanding of the WMATA transit system

After the accident in June, which killed 9 people and injured many others, and the continuing problems with safety, financial problems, lack of a regularized funding system, lack of appropriate regulatory oversight, not to mention problems with how the organization is led from the top (both the Board of Directors and top management), it seems reasonable to have a similar kind of regional transit planning exercise here.

Not only would this restore trust in the WMATA system in the DC region, by building a sense that WMATA is accountable to riders, it would also rebuild a regional understanding of what the system is capable of and how it should expand.

It has been 40+ years since the WMATA Metrorail system was first conceived and 33 years since parts of the system began opening. It's time for an assessment/reassessment.

This ought to be preferred over the grab bag of extension proposals in Virginia and Maryland (with little consideration of the impact on the current system) that the system faces currently.

WMATA only sees the world in terms of subway and bus. So the planning process needs to be broader and deeper, focused on transit generally, not just on WMATA operations as they are set up now.

At the same time, such a process should consider truly regional transit planning (which means including railroad service as an option), and the scope of the study should be broad, rather than overly-circumscribed and limited.

WMATA, in conjunction with the Transportation Planning Board of the MWCOG and the local jurisdictions, as well as MARC and VRE and other appropriate state authorities in Maryland and Virginia as well as DC, should launch a planning process similar to that of St. Louis, to come up with a metropolitan transportation plan that allows for transit services to be delivered where they need to be, but one that uses the most appropriate means (heavy rail, light rail, street car, passenger railroad, different types of bus service) to do so.

It should look at funding issues as well as heavy rail expansion where appropriate. That means not just extending transit service outward, but intensifying transit service at the core as well.

Such a planning process should also consider questions of leadership, management, and oversight. As well as funding.

It's the only way to build a truly regional understanding and commitment to transit for the Washington metropolitan region. Without such a planning process, I think we're destined for a lot more of the same incremental and discoordinated transportation planning that we have today.