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To Whom it May Concern:


Like the XpressWest plan before it, the Texas Central high speed rail proposal is incredibly inept. Now, after lengthy and no doubt costly consultations and review by the FRA and AECOM, and hiring of a civil engineer with a household name to lead the corporate promotions effort, none of the contributing experts has seen fit to clue Mr. Kieth in on the folly of this proposal, which simply has no chance of realization as a going concern.

While Shinkansen is arguably the high speed rail system by which all others are measured it may not be the best alternative when planning for development in certain instances and locales. And this may explain why, when offered dibs on developing service between Ft. Worth and Dallas by TxDOT, Kieth turned them down.(!) It is my belief that having a number of stops between the two cities combined with a one-seat ride through Dallas to Houston would approximately double the number of passengers using the service at-and-through Dallas. And I doubt I am alone in this.

This defect alone is enough to justify totally scrapping and rethinking the plan, and it should have been done a long time ago.

The preferred 240-mile Texas Central route suffers from the now common affliction of high speed design in the Western World - it is circuitous, avoiding civilization where possible while requiring the continuous grinding around of extreme wide-radius curves at speed - thus enabling the high speed but wasting it on the lengthy alignment, and failing to serve the populations in the places avoided, because they are too developed - a characteristic that in Texas Central and several other resent high speed entries has been taken to a point of ridiculousness.

If built, this Preferred Alternative will be a permanent disincentive etched in stone and steel to upgrading and expanding the proper high-speed alignment between Dallas and Houston. (see below ((it's not a matter of taste)) It would essentially double the intrusiveness often complained of concerning rail projects, with a costly and duplicative new-build alignment that is ten miles longer than the existing one.

The proposed Dallas end station appears particularly unpleasant and difficult of access. It is remote from anything visible in the yet-vague detailed drawing where an apparent pedestrian bridge is labeled in the side panel as "Systems". Is the bridge to have a conveyor-belt-people-mover? Of course the Houston station alternatives are all in the wrong place, regardless of the brilliant rendering by architecture student Kiana Karimi. The very idea of using any but the splendid Dallas Union Station - thereby bringing it to complete revival including the main waiting room - is folly that makes you wonder what's going on and who's behind it. All arguments asserting business interests and the need for more sh*tty-geometry trolley tracks pale vis-a-vis the fact that a prestigious high speed service would put this landmark back on the map as a public showplace rather than some private venue for conspicuous consumption.

Disclaimer: I am unable to find any information on the current structural particulars of Union Station and it's surrounding trackage other than what is available from aerial photos and very limited photos of the interior, but am convinced - if by instinct only given a number of other current passenger rail SNAFU's I'm intimately familiar with - that a feasible and aesthetically improving solution exists that would allow high volume long distance service to co-exist with DART at this location, benefiting and allowing further expansion of both - even if it means two levels of tracks.

The point is to work up and solidify plans that include high volume long distance and higher-than-current volume local service, coexisting and conveniently interfaced on location, while taking advantage of this legacy that cannot now or foreseeably be equaled or reproduced. This might possibly be undertaken as part of the project currently known as Core Express. Armed with the said particulars and adequate preparation I would argue against any engineer or interested carrier entity, that a minimum of four completely grade separated tracks from Ft. Worth and the capacity to accommodate the traffic at Union Station, along with that of the Houston service, is not only doable but a necessity. It is only a matter of taking the time to divine the the best solution, truly a rewarding and revelatory process - and most interested parties are suspiciously unwilling to undertake that.


It has been increasingly difficult to ascertain exactly (or even loosely) what is meant by environmental documents found at the FRA website and Texas Central is no exception. I am still unable to pin the one alleged Grimes County station down to any particular location, as with most of the intended route, and have found it quicker to consult an article in the Dallas Business Insider than to struggle on with the 53 PDFs plus the additional documents on other pages.

What page among the reams of PDF's put forth as the Texas Central DEIS would show a reasonably easy-to-view illustration of the Preferred Alternative with it's route and specific geographical context, with stations?

The layered structure of the detailed drawings makes them so time consuming to scroll through as to discourage further investigation. They should have been photographed by FRA and put in a readable, navigable context for public consumption.


There is no legible key, for identification and location of the reams of detailed drawings. I suspect the detailed drawings represent more than one route but without specific labeling and a key showing each drawing's position along whatever route is being represented this is certainly not evident at all.


The FRA has failed to work up intelligible titles for the fifty-three PDFs comprising the DEIS (only part of the December publishing dump related to Texas Central) that would differentiate one from another, and they have failed to make clear the addresses of the web pages where their various documents are located - particularly in the recent email notification of DEIS availability. The usual environmental documents page seems to have two Texas Central projects but this is not the case, forcing everyone to examine both, in trying to find the DEIS.


The FRA's tendency in this direction may end up being subject to legal review at some point if it is not remedied quickly.


The towns along the proposed alignment for a Dallas-Houston high speed line hereunder described for you perusal - some of them quite sizable - are railroad towns. Their existence in many cases was due the the railroad's presence, and their daily life and economic well being were to some degree dependent on railroad-enabled businesses at one time or another, and scheduled passenger service


But now that is a distant memory - and what do they have to show for it?

An antiquated and intrusive infrastructure based on the the post-war business formula of investing as little as possible while illicitly boosting revenue through things like triple-stack freight, heavy axle loads and deferred maintenance - with massive derailments and frequent accidents at grade crossings.These carriers haven't voluntarily removed a grade crossing since before WWII - and far from Keith's optimistic claim of a special form of eminent domain reserved for railroads, the opposite would seem more appropriate in the interest of the public good, i.e. to use it against them. After all, many of these things were originally land grants. It doesn't help when the FRA publishes absurdities such as the following:

"To be located immediately adjacent to but outside of the freight rail right-of-way would require that TCR construct a barrier wall between the freight rail tracks and the high-speed rail tracks for safety purposes. This is to prevent derailment of one service from colliding with the other service. The cost of an approximately 240-mile barrier wall exceeds TCR’s purpose in that the Project would not be economically viable."

There is not much news about the railroads here except the not-infrequent grade crossing accidents and notable massive derailments - and the failure of Texas Central to include an appropriate string of cities and towns in their plans is a symptom of their SNAFU-influenced and thus myopic view of American railroading. It is elitist, inasmuch as the nascent railroad entrepreneurs, tired of the daily grind of getting to the airport, would expect an "uninterrupted" non-stop ride to Houston which would be a fatal misapplication of the passenger rail mode; and it is un-American, in that inclusion of these cities and towns is mandatory - not just because it's right, but because it is a requirement that is essential to generating the necessary passenger draw.



Certain of the express stops shown might be substituted through skip-a-stop service at various scheduled times. Thus, a stop at Palmer rather than Ferris; North Zulch rather than Normangee; and Tomball or Rosslyn Road rather than Willowbrook. The College Station High Speed Connection (red) would require 46 miles of very-low-density right-of-way for its new-build alignments, with the last 4.6 miles in College Station running along existing UP right-of-way having room for four tracks. This would need to be upgraded for grade separation. There is a total of twenty-six stations contemplated along the 230-mile alignment between Dallas and Houston excluding the two terminals.

Between Ft. Worth and Dallas, five new stations are contemplated along the 31.4-mile UP right-of-way. An extensive and expensive upgrade would eliminate all 29 grade crossings including the double-track diamond at Ft. Worth. Such an upgrade has probably been seriously considered, since any new route would  involve still more numerous and insurmountable conflicts - besides claiming precious space where it's not necessary. Lateral straightening does not appear likely owing to the built-up nature of the area, but with a minimum four tracks and complete grade separation the line could be made easily the quickest conveyance between the two downtowns, and with the five stops.

Regarding the Ft. Worth - Dallas segment: the post-war delay in removal of grade crossings has now become the status quo, and "light rail" lines having tracks in the middle of the street (a conscious misuse of the conventional rail mode in other than the most limited, temporary instances) is a ploy used to justify the freight carriers' negligence in failing to address appropriate modernization. So the end result of such an upgrade as Ft. Worth-to-Dallas would actually be nothing special, given proper regulation and compliance with generally accepted 20th Century intentions, leading to appropriate 21st Century norms. The freight carrier would benefit from the upgrade.


The first 4.3 miles in Dallas going south is designed for several tracks and largely grade separated as is.The main north-south line is entered before crossing the Trinity River and would need a minimum four-track upgrade with grade separation to accommodate the stops at Joppa, Hutchins and Wilmer. The new alignment shown above (blue) has existed in the vast majority of its length before, almost exactly as shown, though with probably a single track. (The lines in the pictures generally represent two tracks.) The new shortcut alignment uses a former secondary alignment running about 120 feet to the east of the original SP line, seen also in Corsicana with one bridge still extant. The name Goliad Circle is derived from a street name in the community, and a station there would serve as a bribe causing local values to soar. There are no built conflicts in the area of the picture and little that would be considered intrusive. The southern end of the existing alignment (white) would be shifted slightly west to achieve a speedy and unintrusive reuniting of the two lines going south.


At Ennis the existing line runs off in the wrong direction on an 7-mile tangent, and this state of other-than-optimal modern alignment obtains uninterrupted except for a jog west to reach Corsicana and back again - for the next 44 miles. It is surprising that no connection currently exists between the UP and BNSF lines  at Corsicana because the route from Dallas (59.2 miles) is five miles longer than the one thus afforded, although the route through Waxahachie is probably faster currently, and has fewer grade crossings. The connection shown is three quarters of a mile long. The old connection once followed the route of high-tension wires visible below the connection shown in the picture. It was part of the western sub-alignment of the old SP line mentioned earlier, and  would require some 3 miles of extension north to get a smooth  connection to the existing line.


Here the optimum plan gets heroic - although nothing on the order of the Chinese. The Corsicana tunnel would be extended from a  more-or-less tangent line running south 15 miles from Ennis (blue). The two-track, single-tube tunnel with approximate 35' outside diameter would start opposite the reservoir dam shown (red) with low cover rather than a cut, and continue in bored section to a location east of the proposed Corsicana passenger station on 7th Street, where boring of the approximately 3.5-mile bored section would be initiated. The tunnel would continue south past the  proposed  station in an alignment just under 7th Street, to another  station outside of town at Corsicana Crossing Boulevard, with the  entire  tunnel being 5.75 miles long. Using the grading scheme shown, top of rail would be at least 200' below the vast majority  of the mostly residential buildings the line crosses under or goes  by in passing through the bored section (It passes under three  houses and one church as drawn.) with the two grades working out to  about 1.3  and 1.6 percent. (descending and ascending, from the  north respectively) It's possible a center track with its loading gauge straddling those of the other two could be used for nighttime freight including double-stack, but wheel maintenance would want to be strictly enforced. The proposed abbreviation between Ennis and Kirvin 24 miles south of Corsicana, would take three miles off the old 44-mile route, allowing direct high-speed service and the two below-grade stations in Corsicana, with an additional new station further south.


The College Station High Speed Connection is shown here entering the existing UP line 4.5 miles south of the College Station terminal. Besides the terminal station there are nine additional stops shown within College Station, to insure that anyone traveling to points near or on the Dallas-Houston rail axis would be able to  get there fastest by taking the train.


A station, Richards, is planned off the main high speed line where the College Station line that exits and heads northwest (the curves of which have not yet been drawn) turns out, but not at the analogous location on the College Station line exiting and heading southwest, which exits the main line by way of the existing one. Otherwise no additional stops are planned for the high speed connection due to its sparsely populated route. A somewhat  analogous stop might be achieved at Iola, by having some trains run past the the high speed connection on the old line, then reverse at the station and enter the southwest-headed connection by way of the closing leg of the  wye formed where the connection leaves the old main line, as shown  - which would be 2.5 miles long - the closing leg that is.


No effort has been spared in the search to find the most unintrusive route possible along the fifty-six miles of this longest stretch of separate high speed alignment, which takes 3.3  miles off the original route - as the relatively tight zig-zag at upper left, with points of tangent intersection (as shown) 1.25  miles apart, will attests. Invisible in this picture is the deep cut located right above the Google Earth logo through which a pipeline, that along with high tension wires defines most of the proposed 56-mile alignment, passes. The three tunnels totaling 1.7 miles in length, with two of them flanking the open-air Dobbin Station, would probably all require excavating from above, though  there is some possibility the southernmost one could be bored. The two tunnels flanking the Dobbin express stop would need to have provision for four tracks in case of future developments, and so would add some considerable breadth at this point. The northern one nearly crosscuts a picturesque farm operation directly north of the station, quite closely, but otherwise there are no built/structural conflicts along the 56 miles that I can detect.

The telltale markers for possible County Road and Plank Bridge stations have betrayed my intentions regarding the apparently frequently used BNSF freight line crossing at this point. While this is a touchy subject and impossible to assess without complete investigation it is my believe that a physical configuration could be developed that would benefit the freight carrier logistically in spades - rather than monetarily by payments for trackage rights - to achieve at least partial realization of  the very desirable passenger service that would be afforded by this  line. The high speed station at Dobbin would generate considerable demand for service to Conroe, with many of the suggested stations  showing signs they have been used as passenger stops before. There  are ten suggested stations between Dobbin and Conroe. Likewise, the longer leg to Navasota and on to College Station would revive a very useful service made more so by availability of the high speed line at Dobbin. Navasota would benefit by being tied in to both ends, after decades with lots of tracks and trains but no passenger service.


The BNSF line coming in from the north (left) would be connected to the UP crosstown line by way of a tunnel under Mangum Avenue, with  a station stop at the Northwest Mall. There is plenty of lateral play given four tracks along the incoming line for achieving a somewhat deep grade configuration to pass well under both the  freight track(s) and a sluiceway located directly past them, and this would insure quiet operation as the alignment passes close by residential properties directly to the south. The tunnel is shown  here as having three simple curves with 2500' radiuses (save the  one point-of-intersection node) and the northernmost of these would bring the alignment quite close to the apartments on each side successively, in the interest of tracing a straighter path - but  this would have to be optimized before any thought of realization. The tunnel alignment would propagate to three tracks north of the Northwest Mall station and continue with three passenger tracks to the end of the line.


The crosstown UP freight line was originally a high speed line with 120' right-of-way and a curved alignment having a minimum radius nearly four miles long, but now it has a grade crossing every three  hundred feet. There should be provision planned for six tracks, running from the intersection of the Mangum Avenue tunnel to a  point 4.25 miles east of it, where most of the freight traffic would exit. No flyover or grade separation at this point would be required in relation to the three passenger tracks since they would cross to the south of the line at Mangum Avenue and the freight  traffic would turn out to the north. Thence one and a half miles to the main station.


The station approach may seem a bit odd looking since it zigs then zags - due to existing buildings and configurations I have not  had the inclination to disturb. The large station that existed through the Fifties was subject to to the same constraints. Buildings nonetheless affected are part of the Houston fire and rescue company's vehicle  maintenance operations and as such could probably be negotiated on with the city having the incentive of a beautiful new train  station. The projected station expansion (purple) would add two platforms and two tracks, both of which might gain egress to the east by way of a connecting line that requires alterations to one of the bridges of Interstate 10. Thus there might someday be a station with seven tracks, of which four enjoy through running. Using the existing  bridge leading under the University of Houston Downtown, the second  track from the bottom might be used, with the crossover, for nighttime freight runs to avoid a reverse move. A possible passenger improvement that comes readily to mind in this regard would be a speedy trip to Galveston (about fifty miles) with revival of their main station there. But the grade separation issues of the connection would have to be dealt with (Two different  options exist Galveston-wise for the connection, with one bridge  still in place.) as well as negotiations concerning many other improvements, with the railroad.

The main entrance to the station would be by way of the concave box suggestive of some iconic structure and having curves derived from an earlier site plan, at lower right. Passengers would pass under  the first two tracks from there to reach stairs and conveyances to the platform level, with endlong access to most of the tracks. This would be located on a bridge next to the existing one over North Milam and Travis Streets, or on part of a replacement bridge. An additional bridge, at a higher level, would give access to the University's terrace overlooking the city, as shown. Access to the bottom platform is restricted to its first 250 feet by the Interstate access road, so would require intensive provision for vertical access in a confined area. A wide tunnel would continue under the remaining four platforms, with ramps extending west.

The existing Amtrak/Southern Pacific station - built when they sold the station's land to the post office - would also be equipped with a tunnel, to provide access at the west end, with ramps rising to  the east. Alterations in keeping with the design of the  original 1934 platform shed would be required to accommodate the wider platform. An overarching glass shed or iconic structure, tent or tents might help in achieving the desired tony train station feel. The station is extremely long at 2800' but nothing on the order of those in India. As shown, there are five tracks and four platforms thirty-five feet wide. With Dallas high speed service only half as frequent as currently proposed the station would not seem empty, and would serve to occupy the property before someone gets a hold of it. Some maintenance and cleaning operations could be located in the station, saving on the need for facilities elsewhere. In future years, two not particularly short trains might occupy a single track for boarding, served respectively through the two entrance points, and depart in opposite directions.

            Bruce W. Hain                                                                                                                                                                                                             January 13, 2018

                                                                                                                                                                                                       Queens, New York

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