Dear Mr. Lawler,

The Sierra Club Central Ohio Group (COG) thanks you for the opportunity to comment on the "MORPC-Attributable Funding Recommendations for State Fiscal Years 2008 to 2015" draft list, dated 27 November 2006. We particularly wish to address the Columbus Downtown Streetcar System, MORPC ID 1563.

The Sierra Club is, first and foremost, an environmental organization. As such, we strongly encourage efforts to minimize sprawl, improve air quality, reduce energy usage, and insure the health of waterways and land, thus enhancing human health and quality of life. We support the repair of damage done to cities by past overemphasis on auto travel at the expense of people and neighborhoods. We are pleased that MORPC shares these priorities and addresses them in a regional fashion, and applaud efforts by local governments, other agencies, and private citizens to insure a cleaner, healthier future for all central Ohioans.

Because properly-designed and well-administered mass transit systems can help foster these ends, the Sierra Club strongly supports mass transit. Furthermore, because rail systems involve more permanent infrastructure than bus systems (and, thus, tend to indicate a high level of commitment to transit), the Club is predisposed to favor rail-centered transit. However, because overall system usage, load factor, and financial viability also strongly affect the realization of environmental benefits, it is imperative that any system, rail or bus, be well-designed at the detail level. Unfortunately, many crucial details seem to be missing from the publicly-available information on the proposed streetcar system. Though COG supports a Columbus streetcar system in general principle, we wish to take this opportunity to express concern that a number of issues which we consider highly important appear to be unresolved. Our concern centers on three primary areas of the project as presently defined:

1. Apparent Lack of Regional Cooperation and Connectivity
Effective transportation requires extensive regional cooperation. Just as MORPC is the appropriate coordinator of regional cooperation in an overall sense, the Central Ohio Transit Authority (COTA) is the appropriate regional coordinator for mass transit. We are pleased that COTA is represented on the Streetcar Working Group. But, while we understand COTA's low profile regarding the streetcar prior to the passage of their November ballot issue, we find their non-committal position since the election very troubling. COG would like some assurance that MORPC-administered Federal funds will not be used in any fashion that circumvents COTA's proper role as the lead agency in the planning, construction, and operation of a streetcar or any other mass transit system in central Ohio.

Just as COTA should properly serve as the organizational nucleus for central Ohio mass transit, the streetcar should properly serve as the nucleus for a regional light rail system. All aspects of any streetcar system (track, vehicles, power supply) should be built to standards which would allow the system to be expanded seamlessly into a broader light rail network encompassing, for example, COTA's now-dormant North Corridor Transit Project or similar routes.

2. Potential Harm to COTA's Long-Term Financial Viability
Issue 7, the 2006 ballot measure authorizing a 0.25 percent sales tax for COTA, passed by a very narrow margin. Due to an entirely reasonable perception of past voter antipathy, COTA opted to request temporary, rather than permanent, funding. While reassuring to "swing" voters, this lack of permanence guarantees that COTA's decisions over the next decade will be subjected to a high level of scrutiny and opposition when the levy is up for replacement. Organizations opposed to rail (and to transit in general) can be expected to lump the City's streetcar project with all COTA operations under the general heading of "mass transit," preying on the general public's lack of understanding of the details of agency. Should the streetcar fall anywhere short of the most extraordinary success, this voter confusion is likely to harm all central Ohio mass transit for decades.
The streetcar would also compete for passengers on one of COTA's best-served corridors. In the absence of a high level of COTA involvement in the streetcar project, such competition can only weaken COTA and, by extension, all mass transit in the region.

3. High Cost for Minimal Benefit Compared to Alternatives
As presently proposed for MORPC funding, the streetcar is a stand-alone, downtown circulator system, serving slightly more than two miles of High Street (between Buttles Avenue and Frankfort Street). The lowest publicly-declared capital cost for the system ($64 million) could purchase 200 standard 40-foot transit buses, a number comparable to COTA's entire present fleet. In the absence of broader regional connectivity, the streetcar would provide lower quality service, at significantly higher cost, than COTA could provide with a tiny fraction of those 200 buses.

Any cost-benefit calculation should also recognize the inherent competition for a finite amount of funds among an infinite number of possible projects. Though COG applauds the sense of urgency some central Ohioans feel to begin constructing a rail system, we wonder whether downtown Columbus' vitality and viability might be better enhanced by committing presently-available funds to other, more time-sensitive projects, even if such a choice requires deferring the streetcar for a few years.

As stated above, the Sierra Club strongly supports mass transit in general, and rail-based mass transit in particular. The Central Ohio Group considers a properly-designed and -administered rail system to be a logical and desirable step toward a healthier, more livable region. And, because "the devil is in the details," we hope that MORPC will insist that many more of those details be clarified and subjected to full public scrutiny before committing significant Federal funding to the Columbus Downtown Streetcar Project.