Rail Draft Environmental Impact Statement: Technical Comments

My comments on the City and Count of Honolulu's Rail Draft Environmental Impact Statement (DEIS) were reorganized into two posts. The previous post covered general concerns, and this post covers my technical concerns of the report.

My review was based upon the DEIS section 4F dated November 2008 and particularly of chapter three on transportation impacts. Many of my comments refer to the supplementary report “Transportation Technical Report, Honolulu High-Capacity Transit Corridor Project, Prepared for: City and County of Honolulu, 417 pp, August 15, 2008” which includes much more detail and explanations on the traffic and transportation analyses that were the foundation of the results presented in the DEIS.

• Traffic Analysis Methodology

The traffic analysis method used is not suitable for saturated conditions, and is not suitable for corridor and regional studies. HCM mentions these limitations. Almost all traffic elements along this corridor are oversaturated, thus HCM methodologies do not apply (unless the wrong data are used and degrees of saturation are low.) Either way the output is wrong or misleading.

The table below, in which all black cells are the reviewer’s corrections, shows that general purpose traffic was estimated to be 31% above capacity (estimate of 1.31) but by their numbers, the correct estimate is 62.5% over capacity (estimate of 1.625.) Capacities are not revealed everywhere in the DEIS, so the reviewer cannot check the same calculations in the DEIS.

• Forecasts

Neither the DBEDT (provider of some of the base forecasts), nor the City nor their consultants understand that most growth phenomena in a metropolitan area concerning city expansion and their traffic follow an S-curve depicted by many years of existence as a village, transitioning to a city, several years of growth into a metropolitan area followed by a very long period of maturity with small growth (and decrease) periods. This study erroneously assumes a large future growth for west Oahu and nightmare traffic scenarios whereas Oahu's population, development and tourist attraction have ended their sharp growth and have entered their mature level with a lot of negative bumps along the way. For example, DBEDT Data Book Table 1.06, Honolulu population in 2006 was 906,715 and it dropped to 905,601 in 2007 which was before the sharp economic downturn of late 2008 which is expected to last till 2011.

As shown above, if S-shape forecasts were used, then the unrealistic demand levels shown in the Alternatives Analysis (AA) would never had appeared. However, something inexplicable happened between AA and DEIS: Screenline demands have been reduced by 28% without any explanation. As shown in the table on page 3, demands in the 2008 DEIS are lower by 28% for year 2030 compared to what they were in the 2006 Alternatives Analysis.

Such a discrepancy (28%) in demand produced by the OMPO forecasting model is highly suspect. Qualified alternatives such as TSM and Managed Lanes were dismissed based on high demand figures in the AA which were subsequently modified in the DEIS. A supplemental DEIS is needed to evaluate qualified alternatives with the reduced demand forecasts.

• Were ORTP 2030 Congestion Relief Projects Modeled Correctly?
  

Page 3-16: "Even with $3 billion in roadway improvements under the No Build Alternative, traffic delay in 2030 would increase by 44%".

If one was to correctly model all the committed congestion relief projects in ORTP 2030 (Table 2-3) and combine them with a the fact that Oahu population has been stagnant or falling (and bound to further fall due to poor economy and housing unaffordability), the highway congestion in 2030 could be improve by at least 15%.

For example, the PM zipper alone will carry about 1,500 vph through the Kalauao screenline with 3 or more people in them resulting in a person capacity of 4,500 going west. These are people removed from the existing network thus providing a substantial relief.

The westbound utilization of the rail will be optimistically 6,000 people through the Kalauao screenline of whom at most half will be drivers and ex-carpoolers or 3,000 people.

The PM zipper combined with a Nimitz flyover practically guarantee a continuous trip at 55 mph from Iwilei to Waikele to Kapolei. This commute is half as long in duration as that by rail.

Therefore, the PM zipper alone that carries more persons than rail can be more beneficial that rail. However, the DEIS tries to convince us that major traffic congestion relief projects will yield “peanuts” whereas the rail with its inferior speed and 15+ stops to Kapolei will yield superior travel time savings and traffic congestion improvements.

Part of the reason is likely that planning models are insensitive to bottlenecks and only provide rough estimates based on some assumed values of capacity. Until this author sees proof of use of a regional microsimulation traffic model assessing the impacts without and with correctly modeled ORTP 2030 projects, he asserts that the analysis method was inappropriate and largely incapable in assessing the benefit of the projects in Table 2-3 of the DEIS.

• DEIS Base Travel Times Are Inaccurate

Having resided in Kapolei for a short period if 2007, I know from personal experience that the morning peak period travel time from Kapolei to downtown is always under 75 minutes in the absence of rain or any lane closure. I was startled that the DEIS uses a time of 89 minutes.

I took the opportunity to ask people listening to a radio program that I participate to make some measurements of travel time from the H-1 freeway on-ramp to Alakea Street in downtown if they depart Kapolei between 6 AM and 7 AM. So far I received six qualified measurements of 49, 62, 75, 50, 62 and 59 minutes averaging at about 60 minutes. Therefore, roughly speaking the DEIS uses a 50% overestimate of the travel time which leads to false benefits of travel times by rail.

The DEIS fails to demonstrate the root causes of traffic congestion. The same travelers reported these airport-to-Alakea travel times: 18, 16, 41, 11, 30 and 25 minutes for an average of 23.5 minutes (DEIS uses 25 minutes). The real issue therefore is the traffic flow condition on Nimitz Hwy. which vary widely as these travel times show: 11, 16 or 18 minutes with good conditions, 25, 30 or 41 minutes with poor conditions. This makes it clear that a roughly two mile long Nimitz Viaduct will provide a consistent travel time from airport-to-Alakea of about 6 minutes, reducing the peak hour trip from Kapolei to downtown from about 60 minutes to about 40 minutes. A relatively modest investment solves a huge part of the morning commute congestion.

Note that rail will be providing airport-to-Alakea transit travel time of about 50 minutes (It is 50 to 54 minutes depending on the route selected. The airport route provides the longest travel time for this origin-destination pair.)

• TheBoat as a Threat to the Rail

TheBoat vessel inventory in page 3-31 is wrong. It should also be mentioned that its schedule reliability is poor due to frequent mechanical failures and high seas.

Since we spend the significant amount of $6 million a year on TheBoat, why didn't the DEIS estimate the productivity and congestion reduction of this alternative transportation mode? Will TheBoat reduce rail's ridership?

• Forecasts from the OMPO model

There is a long list of limitations of the OMPO model used to develop the all-important rail forecasts. Here are a few:

1. The model was developed in 1994 by Parsons Brinkerhoff. It is very old in terms of both architecture and data validity. It is also of interest that the same person who developed it as a Parsons Brinkerhoff forecaster now is an Federal Transit Agent who inspects the forecasts.
2. The model has parameters for dead attractions such as the Kodac Hula Show and the Dole Cannery, but has not parameters for Superferry, Ko Olina, Water Adventures Park, North Shore and Haleiwa.
3. The OMPO model is hardly a modern activity-based microsimulation platform. It is an old, aggregate platform with highly compartmentalized trip definitions.
4. The OMPO model depends on many assumed static capacities for various facilities. This makes it susceptible to range errors and easy manipulations. Note that the transit factor table depends on congested times. It would make sense that more people would choose transit from Kapolei to downtown if a time of 90 minutes is used instead of the correct time of 60 minutes. And that was done.

Same concern applies to arterial and freeway capacity which can be arbitrarily set too high or too low to satisfy the objective of the analysis such as “promote rail and undercut HOT lanes.”L

Rail Draft Environmental Impact Statement: General Comments

My comments on the City and County of Honolulu's Rail Draft Environmental Impact Statement (DEIS) were reorganized into two posts. This post covers general concerns, and the second covers technical concerns.

My review was based upon the DEIS section 4F dated November 2008 and particularly of chapter three on transportation impacts. Many of my comments refer to the supplementary report “Transportation Technical Report, Honolulu High-Capacity Transit Corridor Project, Prepared for: City and County of Honolulu, 417 pp, August 15, 2008” which includes much more detail and explanations on the traffic and transportation analyses that were the foundation of the results presented in the DEIS.

• DEIS Does not Assess the Impacts of the Project as Defined to the Public

As described in the Draft EIS, the Locally Preferred Alternative, called the “Full Project,” is an approximate 30-mile corridor from Kapolei to the University of Hawaii at Manoa with a connection to Waikiki. However, currently available funding sources are not sufficient to fund the Full Project. Therefore, the focus of the Draft EIS is on the “First Project,” a fundable approximately 20-mile section between East Kapolei and Ala Moana Center. The First Project is identified as “the Project” for the purpose of the Draft EIS.

This is a hugely critical simplification and it must be rectified with a Supplemental DEIS. The DEIS should have included both the full project and the 20 mile minimum operating segment or fundable project or whatever the City wishes to call it. The people’s understanding is that the rail system is Kapolei to UH with service to Waikiki. The routes beyond the Ala Moana Center are necessary to be assessed in the DEIS. We do not ask the city to assess its mayor’s obfuscations of future rail service from Hawaii Kai to Waianae, but the proposal always has been Kapolei to UH.

A Supplemental DEIS is required to assess the impacts for the whole corridor. It is not possible to begin the system, finish it to Ala Moana Center, and when it comes time to expand it, the expansion impacts are such that preclude any expansion.

• Transit Oriented Development (TOD) Potential Was Not Assessed

A final observation is that people may not realize the unintended consequences around some stations, particularly if they buy property in one of the city's Transit Oriented Development plans. For example, in the Pearl Highlands station, according to the DEIS estimates, over 1,700 vehicles in a day will come to park and take the rail, 300 vehicles will drop off passengers and over 300 buses will drop off and pick up over 8,000 transfer passengers. That's a lot of traffic, and that's station-only related traffic concentrate of the rush hours and this traffic will be on top of all the (heavy) regular traffic in the area.

The question then is... What's the impact of station generated traffic, noise and pollution to TOD potential and TOD plans? Where is the discussion and assessment?

• Over the H-1 Freeway at University Avenue?

This author clearly recalls incumbent mayor Hanneman’s beating of political opponent Ann Kobayashi for her complaining about the rail guideway going over the H-1 freeway on its way to the UH-Manoa campus. Both City and Hannemann vigorously and rudely disclaimed this in the September to November 2008 time frame but then the City presents this image on the official website as of February 4, 2009. the proposed rail clearly overflies the freeway!

• Two Stations at Ala Moana Center?

The Ala Moana Center station arrangement is a mystery. In the 20 mile plan, the station is approximately at the 3rd floor level. In the 30 mile plan the station is approximately at the 6th floor level. What is the exact plan for the Ala Moana Station and how can the guideway expand past the Ala Moana Center given the density, and height of buildings along Kona Street and Atkinson Drive?

This author suspects that roughly half a billion dollars would need to be expended to reconfigure (that is, to demolish and reconstruct) the guideway alignment between Pensacola Street and Atkinson Drive, including the demolition of the 3rd floor station and the creation of a 6th floor station, if rail has any hope in reaching UH-Manoa or Waikiki via Kona Street.

• Why the Double Track by Aloha Stadium?

There is no explanation for this particularly wide double tracking by Aloha Stadium. What’s the purpose, why has it not presented in detail and what is the cost of it?

• OMPO Never Rejected Pearl Harbor Tunnel as Claimed in Table 2-2

The DEIS is wrong in claiming that the Oahu Metropolitan Organization rejected the Pearl Harbor Tunnel. The UH Congestion Study found that this alternative has substantial traffic benefits at a cost comparable to rail’s. There has been no substantiation to the tunnels alleged costs between seven and 11 billion dollars. Viable projects should not be excluded through unprofessional conduct such as out of thin air costing and improper project qualification.

• Federal Funding

The Project’s cash flow analysis, which is presented in Section 6.4, anticipates the use of Local funds for the first construction phase and a combination of Local and Federal funds for the remaining phases.

The project must not start until the full extent of the federal funding is known in writing as part of the next Transportation Act of Congress, and the project should not start until a substantial portion of the federal funding (e.g., a portion that covers half of the cost of the first construction phase) has been actually released for the project. Anything else is simply reckless public policy.

To refresh our collective memory, the Federal Transit Administration retracted their record on decision (ROD) for Honolulu's 2003 BRT plan because construction along Kuhio and Auahi Streets was started prior to completing the necessary Full Funding Grant Agreement (FFGA). Here the stakes are much higher for the local economy and ground must not been broken until the project gets real federal cash (as opposed to political announcements by Abercrombie, Hannemann and Oberstar.)

• How Will the Rail Cars Go to the Rail Yard?

The rail yard is located several miles inland with no direct access to the harbors. Yet the DEIS is silent as to how rail cars and rail equipment will be transported there since rail cars do not fit on regular flatbed trucks and even if they can be accommodated by length and by weight on custom flatbeds, they do not fit by height due to the existence of several overpasses along the freeway. What are the logistics and costs of this significant part of the construction?

• Travel Times by Rail for Political Commercials and for NEPA Documents—Why the Double Standard?

The DEIS clearly specifies that Kapolei-to-downtown travel time by rail is 50 to 54 minutes. This travel time estimate was clearly known in August 2008. Yet in September 2008 the City mailed all residents (using taxpayer funds) a large eight page brochure, the centerfold of which states that Kapolei to Ala Moana Center by rail will be 40 minutes! (For those unfamiliar with the alignment, the Ala Moana Center is five stations after Downtown.)

• TheBus Inventory

In reference to Table 3-12: 2007 Vehicle Inventory, why is this inventory taken from "National Transit Database, 2007" and not directly from TheBusTheBus or the City's Department of Transportation Services transit division that oversees OTS? Why is the total passenger capacity not listed in the table?

At any given time, what percentage of these buses are service ready as opposed to being in repairs or waiting for repairs or parts, or damaged and beyond repair awaiting replacement?

It is my understanding that a lot of buses (about 20%) sit at depots during peak periods and express bus “crush loads” are artificial due to limited scheduling of buses. A case in point is the picture shown above. It was taken at about 6:30 AM on a normal weekday in 2004. The freeway is bumper-to-bumper in the town-bound direction, yet at least 53 buses sit at the depot, many of them articulated (which are typically assigned to the express routes.) How can TheBus “burst at the seams” as a pro-rail commercial claimed in late 2008 when many of the buses sit empty at the depot?

• Unrealistic Fares

To maintain consistency with the travel demand analysis, the actual 2007 average fare of $0.77 per linked trip was assumed to grow with inflation throughout the forecast period.

So the DEIS assumed that fares are the same as TheBus, which given the cost to build and operate the rail, this means that trips are essentially free to users and the general public pays for it. How can this possibly be reconciled with the Council’s desire to cover 30% out of the fare box?

What kind of administrator, engineer and planner does it take to build a five billion dollar transit service and then charge a dollar per ride? I must have this answered so we are able to teach our students this “new math.”

• Ho’opili

The EIS for the Ho’opili project analysis for permit application was done by a consultant other than Parsons Brinkerhoff. It shows projected 2030 freeway traffic conditions with and without rail transit. There's no difference; both are level of service F. It is clear that rail or not, traffic conditions along the subject corridor will be terrible. So the City clearly violated the intent of the NEPA process to clearly inform Oahu’s citizens that rail is no solution to traffic congestion. We all know that the City used taxpayer money to do promote rail as a solution to congestion.

Two Dozen Questions for the City’s Rail Propaganda, Strike That, DEIS

A person in a local government position sent me a list of concerns and questions that the Draft Environmental Impact Statement of the City and County of Honolulu (which simplistically and conveniently narrowed our choices down to steel-on-steel rail and do nothing) should answer but it mostly does not. Any reader of the DEIS will notice that it is big on discussion and small on specific answers and mitigation plans. The owner of this blog did not provide input or alter any information on the following list of 24 items.

1. Building costs are understated, future increases in construction, labor, and material costs are not reported nor mentioned. Also, some of the City's plans for the terminals/terminus are incomplete, missing substructures, rails, handi-access, etc. Was this to artificially deflate the reportable costs? If so the City's entire plan is flawed, and fraudulent.

2. No mention is made of a turn-around or depot. There will undoubtedly be a maintenance yard or some related facility to take the tram down for repairs. This is not mentioned.

3. The Administration has made repeated assurances that the project will be done with minimal impact to neighboring areas, residents, businesses. This cannot be the case. Building and construction guidelines are very specific, requiring x amount of relief space, and will require shutdown of adjoining lots, properties, streets and roads.

4. Many of the people who realized their properties will be (eventually) condemned via eminent domain are under the absolutely mistaken impression that they will be receiving the (at future time) full market value (fmv) of their properties. This is not the case. Research into the City's sojourns into exercising eminent domain muscle reveals that they set aside a lump sum amount, to be paid to defendants served with the Order Putting Plaintiff in Possession (i.e. City). Wording is usually like this: "The sum of $xx,xxx deposited with the Chief Clerk of this Court by the Plaintiff as estimated just compensation..." Usually the award is a few pennies on the dollar of the actual value of the condemned and claimed property. The defendant usually has no recourse. Waianae residents were notified last July that they were losing portions of their property, after construction had already begun for the emergency access road.

5. Regarding property, it is likely the rail system will negatively affect property values. Cities have trended that property values drop near an existing commuter or rail line. The noise negates, for most people, the benefit of proximity to a transit line. Many cities found that rail ridership decreased, in favor of buses, bicycles, and scooters.

6. I personally believe most people would favor a scooter over inconvenience of driving to a depot yard and park their car with thousands of others, to catch a rail to work.

7. The lifespan of a typical rail system is about 30 years. Thereafter, it must be 100% wholly replaced at full value at that future time. It's simply a matter of infrastructure breakdown.

8. The lifespan of a typical tram system (light rail) is about 15 years. Thereafter, it must be 100% wholly replaced, or else repaired to the point where it's economically unfeasible.

9. The mathematics of the City's plan to take 50,000 drivers off the road is not practical nor possible. Let's assume the City is extremely aggressive and forward-thinking in their planning. Let's say they build two rail systems, one that begins in point A (Kapolei area) and the other begins in point B (Downtown). Let's say there are 12 cars to a train (no longer considered light rail), each holding 200 passengers, which is 2,400 passengers total capacity per train, going a single way, or 4,800 passengers for the entire system. Let's say the trains will cross each other in the middle, so there is always a train going and coming in both directions. In order to meet the Administration's goal to take an approximate 50,000 drivers off the road at that future time, the trains will have to travel about 77 miles per hour, nonstop, in order to make the approximate 10 round trips each train will have to make, in an hours' time. This oversimplified math problem underlies the fatal flaw in the plan. The City's plan for light rail does not have the capacity for 4,800 total passengers at any given time. This would be rush hour in the morning, from 5:30AM to 8:30AM, and 3:30PM to 6:30PM. It is not mathematically possible to do it with the above configuration, nor with the City's proposed version, which is much smaller passenger capacity. This may be decried by the Administration as "Mickey Mouse Math" but the figures cannot be doubted. The rail will not accomplish what it is envisioned to.

10. The City's proposed 6,000+ jobs to directly or indirectly support the rail system, operations, maintenance, support services, administration, and vendor services, is not economically sustainable. The vendors have the best bet, at least people will stop on the way to buy coffee, pastries, morning paper, etc. But wait, they can't because the system has to run without stops to make its rush hour quotas.

11. The City's Transportation Department has in effect given their current employees a potential for higher-paying and more executive jobs, "fresh" and new. The current employees are capped where they are at, but the Rapid Transit Division (the most expensive and largest Division by staff and dollars) is a way for them to move up. See their presentation here: http://www.honolulu.gov/dts/dts+fy2008+operating+budget+request.pdf If you scroll down to page 7, you will see "Rapid Transit Division", 35 proposed executive and administrative support positions, costing a whopping $2,338,644 in staff costs, dwarfing their next largest Division by over $500,000, but has only 1 position more. This indicates that, given civil service positions and current pay scales, these are much higher and more executive positions, possibly (POSSIBLY) created this way by the Transportation Department to give their currently “ceilinged” staff someplace to go, and retire happily with a healthy retirement pay.

12. No amount of ridership fees could make up the construction, maintenance, and daily operations costs of the entire rail system. Notwithstanding the payroll costs. The majority of the costs will become personnel-related, such as 41+% fringe rate, immediate salaries plus vacation payouts and other benefits. Throw in maintenance? That's also a personnel cost, with OT attached, at City & County rates. You know, 12 maintenance workers scheduled to perform upkeep, each files OT requests, however only 1 or 2 actually do majority of the work. A recent audit found many road crews operate in this fashion. However the audit was for City internal use only.

13. No amount of taxes can make up the total cost plus ongoing upkeep. The burden on the taxpayers of the state would be astronomical, it could not possibly be estimated.

14. People who voted "YES" did not realize, they were not really indebting themselves, but their progeny, to a lifetime of debt service to this system. It cannot possibly be completed before, say, 2025 or 2030, when most of those who voted will be at or nearing retirement, and it will no longer make a difference for them. Many people simply jumped on the bandwagon without really thinking things through.

15. A raised rail system lumbering many stories above buildings and 1-2 storey homes and apartments in the proposed areas would ruin not just the overall landscape, but many people's enjoyment of the view looking out not to the ocean, but the SKY.

16. The Administration's claim is that if they get this project going now, they can jumpstart the state's economy and provide much-needed jobs through construction. This is short-term a truth, however if there exists no money to begin with, and the Council on Revenue's forecast shows a current year deficit, with factors of debt in the out-years, where is the funding going to come from? It reminds me of a very ambitious building project in Downtown that sat for many years until another investor came by. Only the Federal Gov't can deficit spend. How can you ambitiously plan alternate and future routes (as the Council is debating now) without having any up-front direct revenues, investor venture capital, bond interest, or other form of monies on hand to even "break ground"?

17. Construction costs are years away, when materials, labor, and rates will be much higher. Final completion costs can be many times the $5 Billion thrown in front of the hapless public. And, once construction begins, final completion can be upwards of 20 years away, including the various legal battles and hurdles the City will no doubt face, in battling hundreds of home and landowners, businesses, and action groups. It will be unprecedented in our State's history, and will likely bring embarrassment to us nationally.

18. Speaking of attention, it is likely that people will prefer (as they do now) places such as Tahiti, Fiji, Thailand, and New Zealand, over Oahu anyway. Many tourists surveyed by the HTA recently said they'd never come back if the beaches eroded. What happens if (i.e. by the year 2030) the beach in Waikiki is a memory, hotels are literally flooded, AND there is a lumbering, leviathan, hulking, clackety, metallic silver worm snaking its way through Downtown? Realistically, do you think any tourists would come to Honolulu, except to use it as a springboard from the Mainland USA to their exotic destination in the far Pacific or Asia?

19. Other states that the Administration quoted as having successful rail systems have something that Hawaii will never have, regardless of how much development we want to create - land space. If anything, Hawaii - due to current erosion - can do nothing but lose land space, at least in Honolulu County. In order for the rail to be plopped down, people who are already there have to make way. As our proud and defiant mayor has proclaimed in various ways, "...anyone opposing this will have to just get out of the way..." The first time he said it on TV, we passed it off to his frustration and lack of self-control. Thereafter, it is a clear indication of absolute superciliousness, self-love, and hubris which I do not ever recall seeing in any of our recent mayors of my memory. The sign of a bad publican is to - even modestly - threaten to shove it down the peoples' collective throats when his way is challenged, and his personal progress slowed.

20. The Administration does not inform the public of the following: Chicago Mass Transit (Chicago Transit Authority), one of the original models for an earlier proposed transit system, is bankrupt. If not yet, pretty darn near. The cost of doing business has long overrun the intake due to ridership, which has decreased over the last 30 years. Even their bus ridership is down, largely due to increased crime in poverty-stricken areas near the center of town. Unfortunately for us, Pearl City & Mililani are becoming what Kalihi and Liliha have long been - our native slum.

21. Sound is a pressure wave that emanates radially outward from its source, decreasing as the inverse square of that distance the listener is from it. The City's contention that erecting short walls, combined with the raised platform, will decrease noise to a minimal level, is preposterous beyond laughable. Any system, even a rolling wheeled vehicle, creates a significant amount of noise, and particularly at night. Anyone who lives near the University or along the H-1 between McCully through Pearl City knows this. Even if it is no louder than a small grass whip, it will be noticed, and people will be driven out. I used to live in a small apartment on Thurston Avenue in Makiki, and the simple act of the bus rolling at 11 at night was enough to jolt this young child - at that time - awake from a light sleep.

22. Due to Homeland Security regulations involving public transportation, the City & County would have to establish, and integrate into the Honolulu Police Department, a separate Honolulu Rapid Transit Police force, or else divert current - or future - officers to that duty. Security screens may be necessary at depots as well, adding to delays (but wait, they can't stop right?)

23. The Administration claims that the economy will be stimulated, looking at (i.e.) Denver, Portland, and San Jose light rail development, don't realize that those systems were supported by large tax or other subsidies, something dramatically lacking in Hawaii's economy. Even the current tax collected for transit is far short of proposed levels they would have to be at for the system to be a reality.

24. Finally, no mention is made as to whether this light rail system can accommodate passengers (i.e. from the airport) with large luggage, or whether stowage space is or can be provided for safety, comfort, and security of others?