Solutionary Rail's Submitted Comments to WSDOT on their pre-SDP (April 2024)

April 18, 2024

Comments to WSDOT, regarding their preliminary Amtrak Cascades Service Development Plan

By Bill Moyer

Executive Director, Backbone Campaign
Co-author & lead for Solutionary Rail - A people-powered campaign to electrify America’s railroads and open corridors for a clean energy future

The public deserves the Amtrak Cascades to live up to its purpose, not excuses. It is time for WSDOT to finish the job.

In 1991, the Washington State Legislature provided a directive to the former Washington State Rail Office to craft a plan for north-south service that would draw cars off of I-5. The Legislature established trip time goals to make train travel comfortably competitive with driving between Seattle and Portland (2.5hrs) and Seattle and Vancouver, BC (2.7hrs). These goals embodied the legislature’s vision for the Amtrak Cascades. They were reaffirmed as recently as 2019 in the Washington State Rail Plan, renewing WSDOT’s binding obligation to the people of Washington. 

To meet the legislature’s goals and realize its vision, the state originally commissioned the Long Range Plan (LRP). According to Thomas White, who was centrally involved in the LRP as a rail planner, that plan could easily be updated to meet these goals today. As it stands, WSDOT’s draft Service Development Plan falls far short. In fact, it does not even mention shorter trip times in its purpose statement or acknowledge that its mission is to draw drivers off the road and onto trains. As such, it functions as a nail in the coffin for the Amtrak Cascades. That is unacceptable. 

WSDOT is masking this by making promises without any means of fulfilling them, such as its proposal of running 16 trains per day between Seattle and Portland without making any substantive improvements to the infrastructure. This is particularly laughable when their current on-time performance is hovering around 50 percent, and that’s with a 15-minute grace period. The only way to add that kind of enticing service and make it reliable is with dedicated, higher speed passenger track. To get people out of their cars, train travel has to be comfortably competitive. That means frequent and reliable, with trip times that are faster than driving. Frequent, unreliable, and slow won't cut it.

The groundwork for the Long Range Plan has already been laid, not only on paper, but in practice. As Thomas White makes clear in the April 2024 report entitled Amtrak Cascades Improvement Program, the first phase of the LRP was to unclog the BN/BNSF freight system. WSDOT already worked with BNSF to do that. Much of the $800 million provided by the Obama administration's American Recovery and Reinvestment Act (ARRA) was used to accomplish that work. Once the freight system was functional, the next phase of the LRP was to add nearly 200 miles of dedicated passenger track with speeds up to 110 mph. This would ensure that more passenger trains could be added to the schedule without impeding freight fluidity or having passengers delayed by freight trains. 

Instead of finishing that work, WSDOT is making excuses and attempting a bait-and-switch on the people of Washington State. I was told by the current planner in charge of the rail program that these trip time goals were "no longer necessary, because Ultra will take care of that.” But the UltraHSR concept being pushed by Microsoft is a $150 billion dollar project requiring new right of way and an estimated 90 miles of tunnel. Ultra may take 30 years, or may never happen at all. That was the finding of the JTC report commissioned by the legislature. In stark contrast, the improvements to the Amtrak Cascades system could be completed within the decade. Regardless, a future bullet train is only as good as the intercity rail system it augments, as has been seen in places where it has actually happened. So no, it will not “take care of that.” Ultra is not a replacement for the Amtrak Cascades, even if it does get built.

The other excuse we have heard from WSDOT representatives is that "BNSF won't let us." To start, this ignores Federal Title 49, Subtitle V, Part C, Chapter 243 24308 which describes use of facilities and providing services to Amtrak, federally mandated preference over freight transportation, federally mandated accelerated speeds, federally mandated additional trains. WSDOT should also review this 2019 document on Shared-Use of Railroad Rights-of-Way by Federal Railroad Administration addressing access to and use of railroad rights-of-way, train performance, and measuring public benefits (chapter 2, 3, 4, respectively). WSDOT has a special responsibility to inform - not misinform—legislators with accurate information.  

Secondly, this excuse completely overlooks the agreement that actually existed with BNSF for 20 years. We know from a Public Records Request filed last year that BNSF signed onto a Master Agreement for the very improvements we are asking for in 2003. WSDOT let that agreement expire on June 30, 2023. But as indicated earlier, the public has already lived up to our part of the deal by unclogging the BNSF freight system. It is now time we get the higher speed, dedicated passenger track. This should not be a problem because dedicated lanes for passenger and freight trains remain a better solution for both robust freight fluidity and faster, frequent, on-time passenger service.  This is further affirmed by recent developments in California.

Lastly, California provides additional evidence that WSDOT’s excuse that “BNSF won’t let us” is simply untrue. Clearly, BNSF Railway is willing to work with a state government and other partner public agencies to build the infrastructure necessary, including dedicated passenger track—for up to 125-mph trains on its right-of-way. It is also willing to allow the electrification of train service on its right-of-way with 25 kV overhead catenary wire—even when that right-of-way is shared with its double-stack intermodal trains.  

This last example from California above exposes another glaring deficiency of the Preliminary Service Development Plan and all the plans that preceded it, the potential for an electrified passenger rail service. Though advanced battery technology along with catenary over sections of dedicated passenger track would allow the Amtrak Cascades service to chart a path toward an electrified passenger service, the example from California indicates however that this service may not need batteries at all. In fact, BNSF could be amenable to the electrification of this more robust system. As regulatory requirements such as those proposed by CARB become the national standard, it is likely that BNSF may also shift its source of motive power.  

It is time for WSDOT to stop making excuses and get busy updating the LRP and integrating it into the Service Development Plan for the Amtrak Cascades. In parallel, it needs to renew the Master Agreement with BNSF to reflect those updates.

Considering the level of highway congestion, the perceived need for an additional Puget Sound region airport, and the urgent need to reduce greenhouse gas emissions by 2030, fulfilling the original purpose of the Amtrak Cascades has never been more urgent or important. That is why it is such a serious betrayal of the public trust that—at the very moment when federal resources are finally available—WSDOT is abandoning the founding purpose of the Amtrak Cascades and dooming it to mediocrity.  

Solutionary Rail is locking arms with rail, transit, climate, and public health advocates across the state to demand that WSDOT's so-called Service Development Plan (currently a service under-development plan) include the original purpose, established criteria, and the necessary infrastructure improvements. It must do this by updating and fully integrating the Long Range Plan for the Amtrak Cascades. Submitting this to the Federal Railroad Administration will accelerate the Amtrak Cascades' progress through the Corridor ID Program, as well as allow it to access other opportunities for federal funding, such as CRISI grants to implement improvements to what is clearly an existing corridor. We also demand that the Master Agreement with BNSF be renewed and continue to include the dedicated track and 110 mph speeds that are critical to our mutual success. 

In short, we are simply insisting that WSDOT Finish the Job! To demonstrate beyond any doubt that the Long Range Plan is the way to achieve this, Solutionary Rail and our rail advocacy allies commissioned the Amtrak Cascades Improvement Program 2024 report. The report is the product of countless hours of painstaking effort on the part of Thomas White, who spent years working on the Long Range Plan. WSDOT owes it to the state of Washington to give it full and serious consideration.

Thank you for the opportunity to comment. Please be sure to review and include the Amtrak Cascades Improvement Program 2024 in the public record.


Bill Moyer
Executive Director
Backbone Campaign
Solutionary Rail co-author & campaign lead


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