Excerpts from BATWG’s August 31, 2017 letter to the San Joaquin Regional Rail Commission:

“…BATWG has long advocated a major upgrade to the ACE service between Stockton and San Jose.  For this reason we support the SJRRC’s decision to examine ways of accomplishing this objective. “However, in our view, the ACE Forward DEIR fails to adequately address this vital issue. Here five ways of bringing ACE up to its full potential:

1.)  According to the Fact Sheet accompanying the DEIR, the trip time between Stockton and San Jose’s Diridon Station would be cut from 2 hours and 12 minutes to 1 hour and 59 minutes, a reduction of 13 minutes or 9.8%. Would so minor an improvement result in a material increase in ACE ridership? No…at least not in terms of attracting a discernible number of motorists off the freeways. The ACE service between Stockton and San Jose should be significantly upgraded. The SJRRC should raise its sights.

2.)  In the DEIR, it is also proposed that the trip time between Pleasanton and San Jose be reduced from the current 59 minutes to 52 minutes, a reduction of 7 minutes.  Same comment.  The SJRRC should be shooting for much greater reductions in ACE trip time.

3.)  The need for a more ambitious and farsighted approach to improving ACE’s Stockton to San Jose service notwithstanding, the DEIR’s Phase 2 “improvements” include a 2.7 mile detour off the ACE alignment to a new ACE stop at the Union City BART station.  Union City has long desired to become a regional “transit hub”.  Does one sprawled out allegedly “transit-oriented” development warrant stops by two or even three separate passenger rail lines?  We don’t think so. The DEIR does not address the fact that this detour including train turnaround time would increase the Pleasanton – San Jose trip time by three times the 7 minutes reportedly saved by the proposed near term improvements.

4.)  The DEIR does not include at least two potentially viable alternative ways of connecting BART to ACE in the southeast Bay without the need to send ACE trains off line.  First, a free bus shuttle service could operate frequently between BART’s existing Fremont Station and ACE’s existing Centerville Station.  And second, there could be an elevated, canopied, moving-ramp, pedestrian connection between the Fremont BART Station and a new Shinn Street transfer-only ACE stop. 

As shown in the photos (left photo looking north and right photo looking south) there appears to be enough room to the east of the BART viaduct for a pedestrian walkway.

Describing a favored alternative in detail while failing to address or even mention potentially viable alternatives undermines and contradicts the intent of CEQA that all viable alternatives be considered in EIR’s.

Accommodating Union City’s desire to become a transit hub by detouring the ACE trains 2.7 miles off line would be a step backward, not forward.  Instead of impeding through service the SJRRC should be making every effort to materially improve it.

5.) In closing we wish to repeat that BATWG opposes the push to build a $3 billion plus BART extension to east Livermore, allegedly “to join with ACE”.  Improving ACE all the way to San Jose would be a much more useful use of scarce transportation resources.  Sending a branch of a substantially improved ACE service to San Francisco would provide the additional benefit of easing pressures on BART’s already at-capacity transbay section.

Sincerely,
Gerald Cauthen, Chair
Bay Area Transportation Working Group
510-208-5441
510-708-7880