Friday, December 19, 2008

This Week in Amtrak

Fxbg AmtrakImage by andrew.deci via FlickrThis Week at Amtrak; December 19, 2008

A weekly digest of events, opinions, and forecasts from United Rail Passenger Alliance, Inc.
America’s foremost passenger rail policy institute
1526 University Boulevard, West, PMB 203 • Jacksonville, Florida
32217-2006 USA
Telephone 904-636-7739, Electronic Mail •

Volume 5, Number 32

Founded over three decades ago in 1976, URPA is a nationally known policy institute that focuses on solutions and plans for passenger rail systems in North America. Headquartered in Jacksonville, Florida, URPA has professional associates in Minnesota, California, Arizona, New Mexico, the District of Columbia, Texas, and New York. For more detailed information, along with a variety of position papers and other documents, visit the URPA web site at

URPA is not a membership organization, and does not accept funding from any outside sources.

1) What would our fathers say? Those of us just slightly beyond middle age remember a pre-Amtrak America, when railroads were run by professional railroaders – even the passenger services. The trains our fathers ran were run with a purpose, to either make money for the railroad, or lose as little money as possible for the railroad which had to run trains as mandated by government regulation.

Towards the end of the private passenger train throughout the 1960s, especially at the end of The Pullman Company days, things became a bit dicey, to say the least. But, the passenger rail industry was still in many instances operated as if passengers mattered. The Santa Fe Super Chief was never anything less than super, even the day before Amtrak Day on May 1, 1971. Seaboard’s Silver Meteor never lost its shine and luster.

Union Pacific’s City of Los Angeles kept its dome diner through the end, and even though Arlo Guthrie sang of 15 cars and 15 restless riders on the Illinois Central’s City of New Orleans, the train still provided a good ride.

Even though many railroaders knew (And, some, feverishly hoped.) the end of private passenger service was coming, they refused to lower their standards. After all, those trains still carrying all of those still millions of passengers a year still had the company’s name on the side for all of the world to see.
And, then came Amtrak, the precursor to today’s nationalization of Wall Street, the banking industry, and the automobile manufacturing industry.
Yes, those same fine folks who brought you the Post Office Department and then the USPS now brought you passenger rail service in 1971.

In the beginning, it was pretty-much okay, because a lot of the professional railroaders – who thought of themselves as professional railroaders and not employees of a company which depends on annual handouts of free federal monies – kept on doing what they thought they were supposed to do, which is run trains for the benefit of passengers and the company’s bottom line.
Along the way, our fathers retired or passed away, and took with them the last vestiges of professional passenger railroading. Gone now are what used to be necessities, like equipment held in readiness to handle surge demands or replace unexpectedly bad ordered cars and locomotives. Gone are the extra boards for employees, who were always available to man trains anytime an employee assigned to a regular run wasn’t available for work that day. Gone is the pride in the company, and the pride in the company’s name and reputation.

If you were a Seaboarder, you looked with scorn – or at least great skepticism – at a Coast Liner. The Seaboard Air Line Railroad and the Atlantic Coast Line Railroad were great rivals, fighting for every freight and passenger dollar, but ended up allies when the two companies merged to form what would later become today’s CSX, one of just a series of landscape altering mergers of the 1960s and 70s.

On the Seaboard’s Silver Meteor, every day at 3 P.M. complimentary fresh orange juice was served in the dining car. In addition to a Seaboard conductor and brakeman, the train carried a Pullman conductor, a Passenger Services Agent for coach passengers, and an onboard nurse in a smart blue uniform similar to that of an airline stewardess. (The nurses were allowed during the day to sit alone in Pullman rooms or roomettes instead of staying in the crew car, but were not allowed to close the
door.) On the Coast Line’s famous winter train, the Florida Special, you were treated to a swim-suit fashion show in the Pullman lounge car, displaying the scandalous new bikinis being worn on fashionable Miami Beach, the train’s destination.

There were dome cars aplenty, Pullman lounges of many descriptions, coach lounges, café cars, grill cars, dining cars of both the railroad and Pullman variety, and all sorts of different types of sleeping car space, ranging from upper and lower berths to duplex roomettes to compartments, bedrooms, bedroom suites, and drawing rooms.

For non-Pullman passengers, there were a number of different designs of coaches, plus parlour car seats. Long distance coach seats were truly designed for sleeping, a far cry from today’s back-pain inducing Amtrak seats. Even more importantly, there was a coach attendant for every coach.

Most of this is gone, now. Those who falsely believe passenger train transportation should be treated as a government service (With associated levels of competence often thought of when dealing with government

entities.) – and only a government service – are at the moment winning the day. Amtrak is about as bare-bones as you can get.
The whiners who believe only government can solve problems (At your expense, and mine, and, they also believe they know better than anyone else. If you don’t believe that, just ask them.) have no faith in capitalism (Except where it comes to their own companies.) and no faith in entrepreneurship. These single-minded people are content to settle for a middling status quo, almost content to eat every meal at Denny’s, except when it can be put on an expense account, then the best steakhouse in town is the order of the day.
These are not the people Amtrak needs today as friends, nor as employees or managers. What Amtrak needs are dreamers and visionaries, firmly grounded in the rigors and problem-solving tenants of capitalism.

Today’s so-called friends of Amtrak look at any train and think it’s wonderful. They don’t discriminate between trains which are financially viable, and trains which are a drain on the company. All they see are trains, and passengers riding the trains.
We need to stop here for a moment and talk about New York’s Staten Island ferry, a wonderful piece of government-owned transit which hauls millions of passengers a year. These marvelous ships ply their course hour in and hour out between lower Manhattan Island and Staten Island. At one time these ferries were privately owned, but eventually became part of government. Those of us of a certain age remember riding the ferries for a nickel, and then being aghast when the fare went all the way up to a quarter. For 25 cents you got the best view of New York City available, a brisk wind at your face, and a great ride.

One day, someone in government had an epiphany. They did some honest accounting (Often a rarity in New York government.), and discovered it was costing more to collect the 25 cent fare to ride the Staten Island ferry than it was producing in revenue.

Wisely, New York government made a decision to make the ferry ride free, eliminating the cost of collecting the fare, and everyone has lived happily ever after.
While this tiny microcosm of government sanity works in one place in a transit situation, it doesn’t mean it will work elsewhere.

We’ve said it before in the space, and we will say it again. Passenger rail has the potential to be nearly, or completely self-supporting with the right business model. It’s a business model which includes revenue-rich long distance trains which the public gladly patronizes, and short distance feeder trains which can be subsidized by successful long distance trains. All of this is beyond Amtrak’s current business model, or business models of those who advocate high-speed trains without a good feeder system.

Look at the recent anguish in the news media in Vermont about the annual funding for Amtrak state service. The usual gnashing of teeth occurred, and the media was full of horror stories and the usual claptrap about how the Republic would fall if the service was defunded. In the end Vermont lawmakers came up with the money, but this proved yet again when you depend on public financing for something that has a potential to be self-supporting, how much unnecessary public anguish occurs. You can take it to the bank those Vermont stories did more to keep riders away from Vermont Amtrak trains for fear or perception they were going away than new riders were attracted by the media attention.

2) Those who truly don’t understand or appreciate capitalism quickly try and shout down those with a vision and who deal in reality instead of government largesse. Non-capitalists worry endlessly capitalism may actually work, and better solutions may be found outside of the moldy corridors of large government. Even worse, non-capitalists are often proved wrong when pesky true facts get in the way of their dreams of government domination in all facets of our society.
For the moment, even though Amtrak recorded record drops in ridership last month, Amtrak has an almost unprecedented opportunity to waddle up to the government trough and take huge slurps of federal monies in the now-hallowed name of economic stimulus.

The question is, during this unique opportunity, is Amtrak ready for success? Does Amtrak have a viable business plan and the ability to spend zillions of dollars of economic stimulus money? Even more basic, does Amtrak understand how this perhaps once-in-a-lifetime opportunity for lots of money for new rolling stock, infrastructure enhancements to shorten schedules, new technology systems, and almost anything else anyone can think of can best be used to create a dynamic company which can move closer and closer to self-sufficiency?

3) Amtrak Interim President and CEO Joe Boardman has provided us some glimpses of his vision for Amtrak over the next year. It appears he supports long distance trains, which is excellent, but in the few media interviews available, has demonstrated a tremendous lack of non-focus on Amtrak’s core business. He’s expressed delight at the concept of electrifying rail lines from Maine to Miami, while worrying about carbon footprints. This is not the type of visionary thinking Amtrak needs right now. The visionary thinking Amtrak needs is to take what it has, and make it better, more useful, more passenger friendly, and more financially viable. Things like electrification need to be the purview of the Department of Transportation and the Federal Railroad Administration, not Amtrak.

Another major distraction came in the past few days when Amtrak announced it was competing for federal funds to build an entirely new and passenger-only Northeast Corridor at a cost of somewhere between $30 and $40 billion. This is lunacy. Again, Amtrak needs to worry about its present system, and leave this type of infrastructure investment up to someone or something that has proven to be far more adept than Amtrak at managing infrastructure. A look at Amtrak’s stewardship of the current NEC quickly demonstrates Amtrak’s wholly inadequate management of the resource.

4) Everyone can hope the incoming Obama administration will be more adept than the previous post-World War II administrations at framing surface transportation policy. Since the current policy of every preceding administration is to build highways and airports, and then expand those same resources, it will be interesting to see what becomes of rail and water transportation. While an Obama administration is not likely to try and buck any maritime unions (Which will continue to guarantee most ships are manned by foreign crews; heaven help us in time of war.), we can hope for a new day of looking at rail and water transportation as more important parts of our domestic transportation network than they are today.

If, by some sort of minor or medium-sized miracle, anyone should ever take a look at a broad picture, and start coordinating planning and construction of a combination of transit, regional rail and long distance passenger rail systems, taking into account all future uses and inter-connectivity and the needs of freight haulers, then perhaps a sane transportation policy may emerge. In the meantime, if too many states continue to act independently, likely there will be an unmanageable hodgepodge of plans that begin and end nowhere.

At look at the coordination between Amtrak and Tri-Rail in South Florida shows how two systems can mesh successfully. Former Seaboard stations became poorly maintained Amtrak stations, but those stations are now spiffy Tri-Rail stations housing Amtrak facilities. Parking is greatly improved, amenities abound, and a double-tracking of the old Seaboard main line has helped tremendously with dispatching and on time performance. Everybody here is the winner, especially passengers. Once dingy facilities with marginal platforms have become showplaces for modern and efficient facilities and infrastructure. Everything works smoothly because there is coordination and planning, and, even more importantly, local leadership working for the common good of a regional plan.

This concept applied all over the country is a recipe for success.
As of this writing, it appears retiring congressman Ray LaHood of Illinois is slated to be the next federal Secretary of Transportation.

Other than his ongoing support for union positions and overall support for Amtrak, not much is known about the man who will oversee what may be the largest transportation infrastructure building program in the history of our country. We do know as a Republican he works well with Democrats (Obviously, since he’s going to serve in a Democratic administration.), but he doesn’t have a lot of personal management experience; he mostly is a creature of government service, even before he was elected to Congress.

We can hope he will listen to various proposals and have an open mind to creating a true surface transportation policy beyond building and rebuilding highways.

5) The one man in America uniquely and unquestionably qualified to determine surface transportation policy is former FRA Administrator Gil Carmichael. He was kind enough to share his recent speech in New York City with us. Read and learn.
[Begin quote]
Paper Prepared and Delivered By
Founding Chairman, Intermodal Transportation Institute University of Denver United States Federal Railroad Administrator, 1989-1993


Any realistic discussion of the future of global transportation in this century – and of the role of railroads within that system – requires an understanding of the dramatic changes that have occurred in freight transportation during the past 25 years. A revolution has taken place.
The general public is unaware of it. Far too many transportation professionals fail to understand its scope and significance. Since 1980 a global intermodal freight network has evolved. Today "Intermodal" is the world-wide standard for moving freight.
This global movement of freight is sharply focused on speed, safety, reliable scheduling, and economic efficiency. It builds on the strengths of each mode – ship, rail, and truck – who have become partners in offering service. It makes use of the versatility of the cargo container.
Cargo ships and airplanes span the oceans. The freight railroad is the high-speed, long distance, lowest cost, transportation artery on land.

The truck provides local feeder service at origins and destinations.
Cargo airplanes deliver high-value, specialized freight. Overall, the operational and economic efficiency of freight’s intermodal network dramatically conserves fuel, reduces other environmental impacts, and is significantly safer! It represents the most economically, fuel efficient, and environmentally sustainable approach to transportation.
Railroads are essential to this system – and vital to its future growth.
Today, a doublestack container train leaving a port in the U.S. West Coast can replace 280 trucks, run at speeds up to 90 miles an hour, and afford as much as nine times the fuel efficiency of container transport by highway. In North America the rail mode offers another important advantage. A majority of existing railroad rights-of-way have excess capacity. Furthermore, the rail network was created with rights-of-way of sufficient width to accommodate additional tracks and much more untapped capacity. It is reasonable to foresee doubling or even tripling the capacity of the existing route structure without having to acquire additional land. These existing routes connect all of our cities and ports.

As we ponder other future opportunities, the question of energy supply and cost cannot be ignored. Petroleum was established as transportation’s fuel of choice for two reasons. Historically, it has been available at relatively low cost. Equally important — or perhaps more so — petroleum provides a portable source of motive power. Today, we worry about both the cost and future availability of petroleum fuels. Somewhere out in this century we know that the supply will start to fall dramatically.
Building more highways is definitely not the solution.

What are the options, if any? If fuel-cell technology eventually delivers a reliable power source at reasonable cost, it likely is the most desirable outcome, and could be adopted by both the railroad and highway modes. We know that trains, trucks, buses, and automobiles can run on natural gas. But that too is a finite fuel, and in the United States virtually all of our electric power generation capacity installed within the past 20 years has been gas-fired. A third option, with the most promising future supply, is electricity. In the foreseeable future, the railroad mode is the only candidate for large-scale benefits from electrification among the commercial transportation modes. Electrifying the North American rail system would make sense in a future of oil scarcity. It is not something to be rushed into right away, because the current infrastructure technology to deliver it to the locomotive is expensive to install and to maintain. The major sticking point, in my view, is the source of fuel for the electricity. It would be foolish to install an electrified delivery system for power generated from natural gas, for example, because the gas could be delivered directly to the locomotive. But a rail system run on power from nuclear, solar, windfarms, tides, and the like could in 20 or 30 years time have very strong appeal and possibilities. (There’s no telling what Jet A for airplanes will cost in the last half of this century!) A final point about intermodal transportation and the energy situation is in order. The intermodal concept was designed at a time when oil prices were near 40 dollars a barrel. Prices dropped sharply in the mid-1980s, but rail intermodal expanded anyway. The recent whipsawing of oil prices has people wondering about capital investment. Intermodal freight movement makes sense irrespective of fuel prices. It is the energy-efficient service provider. If prices drop the container will still represent the lowest-cost option. If energy cost again double, intermodal simply will gain more market share. Intermodal systems have become a whole new transportation science.

Our success in freight intermodal transportation points the way to what I believe is the most promising strategy for North American transportation improvements, for freight and passenger, in the coming years. I call that strategy "Interstate II". In the last century we built 43,000 miles of grade-separated four-lane highways – the U.S. Interstate I. On the other hand, Interstate II is a vision of truly high-speed intercity/port travel that is based upon steel wheel on a steel rail, not pavement. It partners the superior safety and efficiency of rail transportation with the strengths of the intermodal system. Interstate II can be built on rights-of-way that already exist because there is ample room. I believe that we must build or upgrade about 30,000 miles of double and triple track corridors capable of running freight trains at speeds in excess of 90 miles an hour. That network would be augmented by as much as another 10,000 miles of high-quality conventional routings. This network would be the basis of Interstate II, a high-efficiency network of steel stretching from coast to coast and from Mexico City to Montreal. With GPS and the new PTC technology we should be able to very safely include passenger trains at speed up to 125 MPH. Such trains can be competitive in city pairs up to 500 miles.

As we consider the future there are opportunities for the application of Intelligent Transportation Systems in enhancing operational performance, optimizing utilization of facilities, cargo security, and promoting seamless freight and passenger transfers at intermodal terminals. The intermodal system requires efficient terminals. There have been significant improvements, but inefficiencies and bottlenecks remain. ITS also has an important role in the overall issue of transportation safety.

As I said earlier, I believe that we now have the technological capability to maintain extremely safe conditions in railroad operations.
That is less true in highway and terminal operations. A safety problem in one mode affects the overall performances of all modes in the intermodal system.

Globally, the intermodal revolution and its current operations have owed a great deal to the private sector. The North American intermodal system of ships, ports, trains, and trucks created by the private sector and designed to be responsive to the needs of freight customers. Most of the capital investments in equipment and terminals have private-sector origins. Some industry experts argue — and I agree with them — that intermodal has succeeded because it was a private-sector, customer-driven initiative. There is a role for government. I think it will be difficult in the United States to meet future capital needs for Interstate II without some form of federal, state, and private-sector participation.

Proposals such as a 25% investment tax credits for railroad capital investment seem to me to be the right way to go because they limit the potential intrusiveness of public officials who are generally ignorant of transportation issues and realities, and whose agendas may differ from the purposes for which the intermodal system exists. I believe that a 25% tax credit will double the class I railroads annual infrastructure spending and dramatically reduce the congestion, stress, and cost to our highways.

I believe that we must be very cautious in defining the future role of governments as participants in this process. In particular, there is talk in the Unites States of reimposing the type of governmental economic regulation that existed prior to 1980. Only after that deregulation occurred did the freight railroad industry in the United States flourish after what had been 80 years of economic decline. Had that regulation remained in place I seriously doubt that the United States would now be part of the global intermodal revolution. The mere threat of re-regulation already is causing the financial community and railroad shareholders to question whether the freight railroad managements should continue to invest capital – because the return on that investment will be jeopardized by economic re-regulation.

Let me close with this. We now know that autos, trucks, and airplanes can not solve the world’s current transportation needs. Our new Congress and President plan to introduce infrastructure work programs to put people to work and restart the country. We have built all the highway systems we need. The focus should be maintaining the existing highways as well as reviving the private sector bus industry. Buses offer the most flexible solution for low density and connector routes. New national transportation programs must concentrate on partnerships with the private sector railroads to build Interstate II in the next 15-20 years.
Investing $100-200 billion will create huge numbers of jobs, stimulate economic growth and provide a beautiful 21st century high speed intermodal freight and passenger system.
[End quote]

6) A sad note in today’s communique. Yesterday, the world lost former Amtrak board member Paul Weyrich at the too young age of 66. Mr. Weyrich had many accomplishments in life and was an ardent conservative supporter of transit and passenger rail. Perhaps what can best be said about him was he was a gentleman with a passion for knowledge and generously sharing that knowledge with others. He was a friend of United Rail Passenger Alliance and many other individuals and organizations.

Russ Jackson, one of the original associates of URPA these many decades, frequent correspondent to TWA, distinguished retired editor of Western Rail Passenger Review, and current editor of RailPAC’s web site wrote this tribute to Paul Weyrich.

[Begin quote]
Reported by Russ Jackson
Paul Weyrich, who passed away on December 17, 2008, was a Conservative.
No doubt about it, and he led his group, Free Congress Research and Education Foundation, into commentaries about many subjects of interest to conservatives in this country. What set him apart as far as rail advocates are concerned was his devotion to improving rail transportation and its associated infrastructure. He served on the Amtrak Board of Directors, and was a member of the Amtrak Reform Council in the 1990's.

He was a RailPAC Patron member for many years, and advocated improvements to not only Amtrak but also light rail projects throughout the United States. He and RailPAC Associate Director Ken Ruben exchanged many e-mails on rail advocacy. Yes, Mr. Weyrich was a "railfan," but like many of us also a "rail advocate."
In the July, 1996, issue of the Rail Passenger Review, of which I was then the Editor, the following article was published on p.5. Many rail advocates/supporters were surprised to learn about Mr. Weyrich:

The article as printed: "Conservatives and Mass Transit: Is It Time for a New Look?" is the name of a new study prepared for the American Public Transit Association by the Free Congress Research and Education Foundation, written by William S. Lind and former Amtrak Board member Paul M. Weyrich. RailPAC member Bob Stevens in Helena, Montana, forwarded a copy for RailPAC to review, and we agree with Bob that "it may help diffuse some of the right wing animosity toward transit." The study begins by saying, "Traditionally, mass transit has not been of much interest to conservatives. Their disinterest stems from three
perceptions: 1) mass transit is a government creation that would quickly cease to exist in a free market; 2) no conservative constituencies use mass transit; and 3) mass transit does not serve any important conservative goals." They go on to point out that each of those perceptions has some truth, but are open to question on conservative grounds. "The dominance of the automobile is not a free-market outcome, but the result of massive government intervention on behalf of the automobile. That intervention came at the expense of privately owned, privately funded, tax paying public transit systems." They say that conservative constituencies are turning to mass transit; "that usually means rail transit or bus on high speed busways," and mass transit can "serve some important conservative goals, including economic development, moving people off welfare and into productive employment, and strengthening feelings of community." But, it must be quality mass transit. Mr. Weyrich and Mr. Lind call for an informed dialogue between conservatives and transit authorities and advocates as, "Together they may find ways to provide better transit service that is also more efficient."
Paul Wilson wrote, Weyrich was, "A thoughtful voice on the right on may diverse matters, and among those were Amtrak and transit policy." In his final daily news column published December 18, Mr. Weyrich said, "It is the worst of times because the Bush administration has turned down 70 some cities which want light rail or streetcars. It is the best of times because Amtrak has set records in number of passengers carried. It is the worst of times because the airlines carry more people on one day than Amtrak does in a year."
The pro-transit movement will miss Mr. Weyrich, as he brought into advocacy many who would otherwise have opposed it.
[End quote]
For all of us who had our lives touched by Paul Weyrich, we extend our sympathy and sorrow to his surviving wife, children, and grandchildren.

7) As an end note to the first item in this issue, yes, my father was – and always will be – a railroader. At 87 today, he retired 25 years ago from CSX. He started as a young man before WW II in his native Norfolk, Virginia with the original Norfolk Southern Railroad, a small road in southeast Virginia and North Carolina, where his brother was an engineer.
My father was a clerk, and, when an opportunity presented itself, he moved over to The Pullman Company in Norfolk, where he also had clerical duties. Two 60 year old photos of a 26 year old version of my father in Pullman offices in Norfolk’s union station hang on my office wall. He held a combo job there, both as a financial clerk, accounting for fares collected by Pullman conductors and dining car revenues, and was also a train inspector.

When an outbound train was backed into the station from the yards, he went onboard and inspected the Pullman cars for cleanliness and made sure everything was in good working order. During the 1960s, in the last years of The Pullman Company, and now with the Seaboard Air Line Railroad as a headquarters manager, he would still "inspect" the various Pullman cars we would travel in around the country, and not be pleased with what he found, especially when departing Penn Station in New York City. Sunnyside yards were never up to his standards for car cleaning and repairs.

My parents took advantage of railroad employee passes, including when they were married in January of 1945. After a ferry ride across Chesapeake Bay from Norfolk to Virginia’s Eastern Shore, they spent their wedding night in a Pullman compartment between the Eastern Shore and New York City, on their way to a traditional honeymoon in Niagara Falls. The story they still tell today is "helpful and friendly" Pullman employees, all buddies of my father, knocked on their compartment door every 30 minutes throughout the night to make sure the happy couple didn’t need anything.

Fortunately for my brother and I, my parents loved to ride the train. By the time either of us reached the age of 21, we had logged over 100,000 miles on America’s premier trains, all in Pullman space. Trains included the Silver Meteor, Silver Star, Silver Comet, North Coast Limited, Western Star, 20th Century Limited, Capitol Limited, Golden State, City of Los Angeles, and many, many others. My parents and I were on the last Seaboard Coast Line Silver Meteor out of Penn Station in New York on April 30, 1971, and awoke on the first Amtrak Silver Meteor arriving home in Florida on May 1, 1971. Somewhere in North Carolina at the stroke of midnight, suddenly, Amtrak arrived for us. Prior to that, those early, pre-Amtrak days provided a view of America not readily available today.

So, speaking of our fathers’ passenger railroads is personal. The work ethic of that generation (My father worked full time and overtime at The Pullman Company all during World War II, and still found time to spend several shifts a week working at Langley Field’s coastal defense command in Norfolk as a volunteer since he wasn’t able to serve in the military.) is legendary, and their personal standards were often superb. They were the generation that learned from the Great Depression, and vowed to never have to live through those conditions, again. Their goal was a better world and a better place for their children to live and prosper.
We need to make sure we never let this generation down by being satisfied and comforted by a shoddy product such as is offered today by Amtrak. We can – and must – do better.
Merry Christmas! and Happy New Year! to all, and Happy Holidays! where necessary.
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J. Bruce Richardson
United Rail Passenger Alliance, Inc.
1526 University Boulevard, West, PMB 203
Jacksonville, Florida 32217-2006 USA
Telephone 904-636-7739

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