Wednesday, March 25, 2015

Dear Washington State Dept. of Transportation:

Washington & Idaho Railroad operates the former NP Palouse & Lewiston branch.  At Palouse, WA, March 2011


The State of Washington owns over 200 miles of agricultural railroad in Eastern Washington, known as the PCC Rail System.  The State then contracts with three separate railroad operators who service separate segments of the system. In addition, the PCC Railroad Authority, comprised of county and port district officers from the areas served by the rail lines, has some level of oversight on how the lines are managed.

Recently, the Washington State Dept. of Transportation (WSDOT) published a draft strategic plan for the PCC Rail System outlining its plans for maintaining rail service on the system.  Public comment to the draft plan are being accepted through April 2, 2015, which WSDOT will then incorporate into a final strategic plan sometime soon.  Here's a link to the web page where the plan is discussed, with further links to the draft plan itself and the comment page:


http://www.wsdot.wa.gov/News/2015/03/33_PCCdraftplan.htm


I read the draft plan, and although it seems to mostly make sense to me, I decided to chime in with a few of my thoughts.  I wrote the following letter and posted it to their comment page.  No telling if my thoughts will have any impact:

Dear WSDOT:


Thank you for making your draft strategic plan for the PCC Rail System available online, and for accepting public comments on that plan.  I have read through the report, and I do have a few comments.  I am a private citizen with a personal, but no direct economic interest in the long-term growth and development of the Palouse region.  I hope to see increased employment opportunities in the region, both inside and outside the agriculture sector, so that families who choose to live in the Palouse may do so without concern for their long-term livelihood.


Jobs require businesses, and the businesses with the greatest potential employment needs are often most productive when they can choose railroads for receiving or shipping their various commodities (as your report mentions on page 3).  I applaud WSDOT’s far sightedness in acquiring the PCC Rail System in the first place to ensure rail access to Palouse area grain shippers.  For the most part, I believe the strategic plan you have outlined covers most of the issues vital to the system’s longevity.  And if this plan is followed closely, I believe it will result in many long-term benefits to the Palouse region and its families.


There are a few items that caught my attention and that may warrant some changes to the final draft:
There are a couple places in the document where mention is made of rail service to Moscow, ID (page 9, for instance).  For most readers, it is a small technicality that the rail line only extends to the now-defunct fertilizer dealer at Wilson, WA, just across the state line from Moscow.  Still, it may be helpful to address this so that no future misunderstandings result.


I applaud the acquisition and re-use of rail materials from the former Hanford Railroad for repairing and upgrading the PCC system (page 44).  I actually work at the Hanford site, and am pleased to know those loads of ties and rails I see leaving the site are going to good use.  Similar opportunities in the future must be sought after and seized.


This is my primary issue with the report:  I am greatly concerned by the potential for rail removal on the Colfax to Pullman line segment that is suggested on page 57.  I do not believe “rail banking” necessarily requires rail removal, but that is often what a community comes to expect when that term is mentioned.  Recreational trails are, of course, a very common re-purpose for rail-banked routes.  However, once the rails are removed and a trail laid in their place, it is nearly impossible for those rails to be re-laid without years of lawsuits and related hassles.  How can a potential rail customer be expected to bring their jobs to any community when they realize that the needed rail service is years away?


Rail-banking may still be the right answer for the short term, but I believe it will be a big mistake to allow any community-based entity or organization to replace the rails with a recreational trail.  I can foresee many individuals and groups, especially among the population of students and families living in Pullman, who will want a trail.  But for the community’s long-term wellbeing, WSDOT needs to make it their policy not to allow rail removal from that route, and to stick to their guns on that point when approached by potential trail builders and users.


Of course, I understand the main reason for rail-banking the route is to minimize or eliminate the costs involved in maintaining the route.  However, looking at the few instances when rail service has been re-established on a line previously embargoed or abandoned, the costs involved in restoring that service have usually been several times the amount it would have cost to provide minimal upkeep.  One alternative to rail removal that would provide a small offset to the maintenance costs would be making the route available to rail cyclists.  This service is offered on the public-owned line between Enterprise and Joseph, Oregon (see their website at jbrailriders.com).  I’m certain it’s not a big money maker, but it is a reasonable compromise between rails and trails, and may draw additional riders from outside the area because of its uniqueness.  After all, Pullman and Colfax are a little easier to get to than Joesph, OR.


Another key reason why that route should not have its rails removed is to maintain access to both major Class One railroads.  I am under the impression that both the W&I and PCC (WATCO) railroads have contracts with BNSF and UP, respectively, that compel the shortlines to deal exclusively with only the one Class One connecting line.  To truly address competitiveness and capacity issues on the Class Ones (page 46) I believe it is necessary to maintain the Pullman-Colfax route toward the day when these contracts may be re-written to allow either shortline access to either Class One.  That also should be a point WSDOT addresses – encouraging the Class Ones to re-negotiate with the shortline operators to allow more open access.


Your report mentions the possibility of catastrophe (page 48), and maintaining the Pullman-Colfax link may prove wise if the worst ever happens.

A video I shot on the Pullman-Colfax route in question back in 1998

Also, the line segments between Fallon and Wilson, and from Palouse to the State Line, should also be maintained.  Although WSDOT has little direct interest in providing rail service to customers in Idaho, there is still a positive effect to many Palouse families and communities when their neighbors across the line are thriving economically.  Maintaining access to Bennett Lumber and other shippers that may locate in the Idaho Palouse should also be important to WSDOT.


Additionally, WSDOT should pursue the possibility of shuttle trains from smaller on-line elevators to the McCoy grain terminal as another way to minimize heavy truck traffic within the Palouse region.


Finally, I believe the Grain Train program has been immensely successful, and that program should be expanded as resources permit to make more dedicated-service grain cars available to Washington grain shippers.


Thank you again for allowing public comment on this document.  I believe it is a solid and viable plan that WSDOT has laid out, and with a few minor adjustments, it can establish a foundation for strong economic growth in Eastern Washington.


If possible, please let me know when the final report comes out.  I look forward to reviewing it.


Sincerely,
Thomas Hillebrant
Richland, WA


WATCO-owned Palouse River & Coulee City RR still operates the PV-Hooper segment of the PCC Rail System.
Near St. John WA, June 2012