What’s Alan Lowenthal’s HSR Game?
Another holiday weekend, another trip to Orange County, another time I desperately wish for HSR. Those who doubt the public desire for HSR probably haven’t driven across our state lately. The Berkeley ITS study made much of the cost comparison between driving and taking HSR; yet apparently they didn’t consider the time comparison. 7 hours in a car versus 2-3 hours in a train (depending on destination) leaves the train looking a hell of a lot better, especially in a digital age. And I’m sure that the parents among us can explain why it’s vastly preferable to spend just a few hours on a train as opposed to most of your non-sleeping day in a car with a toddler.
On the drive back to Monterey today, my wife and I decided to break things up with a stop in Santa Barbara, a town my wife had never actually been to (multiple trips through it on Highway 101 notwithstanding). We wound up parking a block away from the Santa Barbara train station, and as we walked toward State Street and the beach, we saw Pacific Surfliner #763 arrive at the station and disgorge a big load of passengers, who promptly headed toward the shops and the beach.
Those passengers and local businesses know well the benefits of passenger rail service, and would likely all immediately and instinctively understand the benefits of a train that was nearly three times as fast as the Surfliner, a train with frequent service that was rarely, if ever, delayed.
Unfortunately, there remain many people in California who refuse to look at HSR’s global success or at California’s own passenger rail success (the Surfliner is a wildly popular train, second busiest in the Amtrak system, and the Capitol Corridor is the third busiest with a record of reliability and high ridership). Instead they remain absolutely convinced, for reasons that we may never know, that HSR will be a failure in California. And some of them seek out evidence to confirm this pre-existing conclusion.
That description seems to fit State Senator Alan Lowenthal. Longtime readers of this blog know that we’ve been very critical of the chair of the Senate Transportation Committee for his repeated statements that obfuscate the truth about the HSR project. He claims to be an HSR supporter, but this appears to be merely the case so he can criticize and undermine the project without being seen as an outright opponent, in which case his criticisms could be more easily dismissed.
One of his most notorious anti-HSR statements is his frequent assertion that HSR ridership numbers “don’t pass the smell test”. Lowenthal made these statements often in late 2009 and early 2010, without offering any evidence to back them up. It was an entirely inappropriate thing for a state legislator to say, but Lowenthal not only went ahead with it, but he got his colleagues to order the Berkeley ITS ridership report partly on the basis of his claims. That shouldn’t be seen as a coincidence – Lowenthal must have known that Samer Madanat, lead author of the study, was an HSR critic based on the flawed report he wrote last fall. It seems plausible to believe Lowenthal handpicked Madanat to lead the ridership report on that basis.
Why? So Lowenthal could set up the strawman he could then knock down. Lowenthal had no evidentiary basis for his claims about HSR ridership numbers “not passing the smell test,” but now he does. And once the study was released last week, Lowenthal wasted no time at all in using it to justify his attack on the HSR project.
Which is bad enough. Worse is that Lowenthal went FAR beyond the actual conclusions of the report to make accusations that even Madanat himself refused to make. Here’s Lowenthal quoted in Mike Rosenberg’s article on the ridership report:
“This is quite an indictment. Nobody was watching the store,” said state Sen. Alan Lowenthal, D-Long Beach, chairman of the state Senate Transportation and Housing Committee, which called for the report and has been overseeing the high-speed rail project. “It makes you think after reading this that they told (their consultants) that they wanted certain things to come out in a certain way.”
Make no mistake, Lowenthal is accusing the CHSRA of telling Cambridge Systematics to cook the books of the ridership study to produce the numbers the Authority supposedly wanted. This is an enormous charge, and if true would likely warrant a criminal investigation.
But Madanat explicitly disavowed that possibility. See Michael Cabanatuan’s article on the ridership report from Friday:
Madanat said, however, that the report’s conclusions and criticisms should not be seen as evidence Cambridge Systematics rigged its report to show higher ridership figures, as some high-speed rail opponents have suggested.
“This is the best firm in the business,” he said. “They have a reputation to protect. I would not say, and I would have a hard time believing, that they skewed the numbers. And there is no evidence of that.”
Unfortunately, some gullible folks fell for Lowenthal’s gambit – like Nathanael Johnson, the SF Gate blogger we discredited on Friday. Here’s Johnson’s update to his blog post from Thursday:
This is what sources have been muttering to me for a while now, but no one has wanted to come out and say it on the record. It’s probably a little more complex than this. First of all, there’s no “they” here. There are a bunch of different people facing various pressures – and placing different pressures on consultants. But it has been definitively demonstrated that planners usually understand which side their bread is buttered on, and frequently produce results that will keep the butter flowing (to extend the metaphor).
Wow. Just…wow.
That is an extremely unprofessional post. Johnson mentions unnamed “sources,” so we are unable to verify the veracity of who has been feeding him this information. I’ve heard the same things, but it always comes from HSR critics, many of whom post on this blog. I’ve never heard anyone actually involved with either the Authority or Cambridge Systematics make these claims. It is deeply irresponsible for Johnson to repeat this without evidence.
As you saw, Johnson then went on to slam the entire ridership modeling industry as being nothing more than a bunch of hacks paid to provide whatever numbers their clients want. This sweeping accusation is accompanied by no evidence whatsoever, just Johnson’s assertion that it has been “definitively demonstrated.” That claim needs more than just a “citation needed” tag – it ought to be stricken entirely by Johnson, who should know better than to toss around insinuations and blanket accusations like that.
But that’s the sort of thing that Lowenthal enables when he too tosses around accusations that he can’t or won’t back up with evidence. And he does this in the name of an ostensible HSR supporter, even though his statements and proposals tend to undermine the project.
There’s a name for this kind of behavior: “concern trolling”:
A concern troll is a false flag pseudonym created by a user whose actual point of view is opposed to the one that the user’s sockpuppet claims to hold. The concern troll posts in web forums devoted to its declared point of view and attempts to sway the group’s actions or opinions while claiming to share their goals, but with professed “concerns”. The goal is to sow fear, uncertainty and doubt within the group….
For example, James Wolcott of Vanity Fair accused a conservative New York Daily News columnist of “concern troll” behavior in his efforts to downplay the Mark Foley scandal. Wolcott links what he calls concern trolls to Saul Alinsky’s “Do-Nothings”, giving a long quote from Alinsky on the Do-Nothings’ method and effects:
These Do-Nothings profess a commitment to social change for ideals of justice, equality, and opportunity, and then abstain from and discourage all effective action for change. They are known by their brand, ‘I agree with your ends but not your means.’
Lowenthal appears to be the leader of the concern trolls, at least when it comes to California HSR. Unfortunately, he’s not just some random dude, but is the chair of the Senate Transportation Committee, where he pledges to grill the Authority at a hearing this coming week. These hearings give Lowenthal power over the Authority. But it also raises a question about Lowenthal’s own long record of misleading statements against the HSR project:
Quis custodiet ipsos custodes?

Brown/Engle might have an answer for lowenthan game
Risenmessiah Reply:
July 5th, 2010 at 11:25 am
Possibly, but the real question is who would assume control of the Transportation Committee after Lowenthal leaves the Senate in 2012… I have a hard time believing that Lowenthal, a huge advocate of reduced greehouse gas emissions wants HSR to fail outright. In fact, I bet if Meg Whitman becomes Governor, Robert and the gang will be embracing Lowenthal as their savior.
And we as HSR supports can ask him to explain..if not the media can grill him
rafael Reply:
July 4th, 2010 at 11:35 pm
Except “the media” won’t, because the false narrative of a heroic legislator standing up to big bad CHSRA is supposedly more compelling.
Lowenthal’s beef has never been with HSR as such, at least not publicly. Rather, his pet peeve is that he is not in charge of the $9.95 billion attached to the project. We can only hope that his overinterpretation of the ITS’s conclusions expose his lust for unbridled power for all to see.
morris brown Reply:
July 5th, 2010 at 9:31 am
Such comments from you Rafael, I would not have expected.
What evidence do you have to back up these claims?
While I’m here, Dan Walters writes:
http://www.sacbee.com/2010/07/02/2864512/dan-walters-projections-of-bullet.html
“From its inception, the project has appeared to be a political boondoggle a solution in search of a problem. The UC report is the latest bit of evidence to that effect. Unless the gaping holes in its viability can be bridged, the bullet train should be derailed. ”
Of course the gaping hole will not be bridged and indeed the project should just be killed.
rafael Reply:
July 5th, 2010 at 9:51 am
Lowenthal has consistently complained not about HSR per se but about the individuals on the CHSRA board and ow they have managed the project.
As for Dan Walters, he’s entitled to his opinion. I’d like to see him examine the viability of the alternative, i.e. lots of new runways and highway lane-miles. Berkeley ITS did in fact not conclude that the project isn’t viable, merely that there are so many assumptions baked into any ridership model that it makes for a poor basis to render a decision either way. That’s debatable, but fact is ITS declined to articulate any forecast numbers of its own.
Brandon from San Diego Reply:
July 5th, 2010 at 9:52 am
The CHSRA project is following script to a “T”.
All large/expensive projects have naysayers and supporters. Those against will throw all kinds of mud… it doesn’t matter the type, but how much. That mud also includes disparaging remarks towards the professionals involved. It’s a game. It’s politics.
But at the end of the day… the project a moving along on a course that was pretty much set at the beginning.
political_incorrectness Reply:
July 5th, 2010 at 11:34 am
That is what this project proposal has deteriorated into is a mud throwing contest and hope something sticks to get it shut down no matter what is posted. The media has failed at its job to look at what the alternative is because as Robert has emphasized, “the cost of doing nothing is not zero”. As always, megaprojects are looked on as boondoggles, overbloated, and unecessary. In some cases, there are better alternatives than what is proposed (BART to San Jose and Livermore), then there are those whose times has come.
If there is ever an op-ed piece done by HSR supporters I’d emphasize a few things
1) The cost of not doing this project is not zero, interstate transport needs will have to be met at some point in order to keep the state economically viable
2) The budget deficit will grow anyways regardless of whether the project goes forward or not.
3) Aren’t bonds bought out by certain people, not by all the citizens of the state?
4) CO2 for construction of 5 runways, 80 airport gates, and 3000 lane miles of limited-access roadways versus high-speed rail plus the cost of maintenance comparison need to be put against each other as the media has failed to do so.
5) This is NOT ACELA. Acela uses OLD TRACKS, this is a dedicated and actual High-speed line. It makes sense that it would achieve higher ridership than Acela, especially with fares in the $100 range instead of Acela’s regular $200+ range.
6) Spain’s numbers on Madrid-Seville and Madrid-Barcelona show that people do switch modes. Not in huge droves but reduction in vehicular traffic of about 20% is still a good chunk of traffic.
7) Fares: The media believes fares have gone up, again, they are still playing out scenarios, I would probably do what SNCF did and start fares lower to build ridership as SNCF did so the TGV did not look like a train for the rich.
I’d write it, but I have less credibility not knowing California politics. I am two states away in Washington state and I want HSR to happen, but there needs to be some myth clean up, more cooperation with the freight railroads, and make the Authority look better instead of an organization with its head cut off.
Robert Cruickshank Reply:
July 5th, 2010 at 12:39 pm
You’re in WA? Welcome! I lived there from 2001 to 2007, in Seattle.
I’ve submitted a few op-eds to different papers, and so far none have yet been published. They’ve generally followed the guidelines of what you’ve proposed. It seems like a good time to try again.
Joey Reply:
July 5th, 2010 at 10:11 am
Why does nothing you post seem to convey any new information?
Robert Cruickshank Reply:
July 5th, 2010 at 10:13 am
That’s Walters’ opinion, and not fact. You can’t cite opinion as fact.
Peter Reply:
July 5th, 2010 at 10:25 am
You can if it supports your personal bias. ;)
YesonHSR Reply:
July 5th, 2010 at 10:59 am
He (Walters) is terrible since before the election non-stop twisted facts and his personal opinion..I emailed long ago –of course no reply
YesonHSR Reply:
July 5th, 2010 at 11:51 am
It not going to be..nor should it be for such a biased report..for of all things the year 2030 when many of these nasayers will have past away and we have to live with what that reality is going to be.
Peter Reply:
July 5th, 2010 at 3:54 pm
How are Rafael’s comments any worse than Lowenthal’s accusations that the Authority conspired with Cambridge to intentionally skew the numbers?
D. P. Lubic Reply:
July 5th, 2010 at 10:13 am
We could be looking at the generational idea again. Lowenthal was born in 1941, which makes him 69 (my estimated low break point is currently about 59); he may support the idea, but find the numbers look too good to be true, even when they are true (“That can’t be right! This is America, people don’t ride trains, even if we do need them!”).
How old is Dan Walters?
About the news media in general: It’s main purpose is to sell newspapers with ads, and electonic media essentially does the same. This leads to the old sayings from the papers, “If it bleeds, it leads. If it smells, it sells.”
adirondacker12800 Reply:
July 5th, 2010 at 10:34 am
This is America, people don’t ride trains
….except of course the people, Americans mostly, who ride American trains.
Peter Reply:
July 5th, 2010 at 11:01 am
This is America, people don’t ride trains
They ride horses. Or when they do ride trains, it’s the Iron Horse, and they shoot buffalo from the cars.
D. P. Lubic Reply:
July 5th, 2010 at 2:02 pm
What’s funny is that some of us do ride behind the “big iron horses,” and in some cases those tourist and heritage roads do perform a transportation function. The Strasburg Rail Road in Pennsylvania does handle freight service on occasion, and will sometimes do so with steam power. And the Durango & Silverton, a narrow-gauge road in Colorado, will also stop its steam tourist trains in parts of the Rio de Las Animas Gorge to drop off and pick up fishermen at otherwise isolated spots–just like they did over 100 years ago.
Two urban examples of heritage rail lines are the cable cars in San Francisco, and the same city’s F line to the Fisherman’s Wharf.
We can use the heritage stuff, too, in the right places. . .
http://www.youtube.com/watch?v=_cC7NlSRgv4
thatbruce Reply:
July 5th, 2010 at 5:04 pm
Colonel Stamp Proctor, is that you?
Im thinking why not have someone independt go over the numbers besides UC Berkley since they are in state and whoever authored the report could have the same conclusion as Lowenthall. If an independent or other 3rd party was able to verify results from other experiences in HSR, then there might be room to discredit Lowenthall. Also, it might be worth it to put some pressure on Lowenthall, find other slip ups.
Matthew Reply:
July 5th, 2010 at 5:01 am
I suppose SNCF and Siemens have already done some in house work. Here’s a report suggesting SNCF predicts 65 million riders per year by 2040: http://www.thetransportpolitic.com/2009/09/19/breaking-sncf-proposes-development-of-high-speed-rail-in-midwest-texas-florida-and-california-corridors/
That’s definitely within the ballpark of the CAHSR figures. I suppose a world leading company that’s planning a serious investment in North American high speed rail can’t be trusted either. The point is that independent modeling efforts are coming up with similar numbers. We can certainly have an academic debate about how to best estimate future ridership, but multiple best practice efforts corroborate each other’s results. I don’t think that further modeling will give a more accurate estimate of ridership, but it will waste a lot of time and money. I think it’s fair to guess that there will be mid tens of millions of riders per year by the early middle part of this century, and I will be one of them. This really seems like a tempest in a teapot.
rafael Reply:
July 5th, 2010 at 7:59 am
Agreed, especially since the Berkeley ITS team did not give any rival numbers. They meekly concluded that the uncertainties were so great that any forecast was likely to be wildly incorrect, i.e. ridership modeling is fairly pointless. This is known as a cop-out, they could have said, e.g. X +/- Y million in 2035 (90% confidence band).
This would have given lawmakers a fairer sense of the scale of the ridership risk inherent in the HSR project. Cambridge Systematics, i.e. CHSRA, never claimed their predictions were spot on. Unfortunately, “journalists” and laymen tend to quote forecast numbers as if they were hard when in fact they are inherently very soft. Plug in e.g. X=60 and Y=20 and actual ridership could be as low as 40 million (indicating an operating loss) or as high as 80 million (indicating wild success). The actual outcome will depends on many factors, incl. actual population, the price of oil, attitudes toward public transportation, availability of connecting transit, discounts for frequent riders (e.g. long-distance commuters), rival transportation technologies, rival communications technologies, general affluence etc. etc. etc.
What if someone had asked you in 1985, i.e. 25 years ago, if in 2010 you’d be reading a blog on high speed rail in California via a wireless broadband internet connection for your personal multi-processor computer? You’d probably have told them to take their meds and call you in the morning. Well, 2035 is 25 years hence from today. Anyone who claims to have – or demands – a perfect crystal ball that far out simply isn’t living in the real world.
Forecasts are always wrong, especially the ones about the future. The preponderance of the evidence from elsewhere in the world is that HSR systems do turn a healthy operating profit IFF fares are set to maximize revenue. They cannot, however, service the debt on their starter lines if those operating profits are ploughed into network extensions, which is what voters usually demand.
morris brown Reply:
July 5th, 2010 at 8:56 pm
Rafael, Elizabeth is the expert here, and I hope she will comment, but Berkeley could only do what they did because, as I understand it, they don’t have access to the software/model. That is owned by Cambridge and they are not releasing it.
So “meekly concluding” was the best they could do. No they could not have said X+/-Y million in 2035 because the model is not available to them; in fact not available outside of Cambridge.
Alon Levy Reply:
July 7th, 2010 at 1:52 pm
So far, nothing Elizabeth has said indicates expertise. She sounds like a hack who’s done a lot of homework. It’s a step up from Cox and O’Toole, but I’d still take the word of someone who can actually talk about a quantitative debate using quantitative arguments.
political_incorrectness Reply:
July 5th, 2010 at 7:59 pm
SNCF used the same Cambridge model that the CHSRA used but you could claim that SNCF being interested in investment is a sign of confidence. I also agree with rafael’s point in that this project will take time and you would never imagine what could happen quite a ways away from now. Therefore, we need to look forward to the future and prepare for a much less oil dependent transportation system. I think bringing up the economic factor of what an oil crisis could do to California would really make people move to getting HSR on the agenda. High oil prices would cripple the tourism industry and outside investments, long distance travel would decline significantly, and many businesses would be negatively effected due to most products being transported by truck. Basically, the alternatives still have major liabilities not addressed being the next oil crisis that could cause a rapid recession.
adirondacker12800 Reply:
July 5th, 2010 at 8:20 pm
Most products that get shipped by truck will never be shifted to high speed rail. Freight doesn’t care if it takes a day and a half to get from the Port of Long Beach to Sacramento.
rafael Reply:
July 7th, 2010 at 3:09 pm
That’s probably an oversimplification, considering the brisk overnight business FedEx, UPS etc. are doing. There are lots of different types of freight, not just the lowest-cost-per-ton heavy bulk and container freight that US freight railroads have decided to specialize in.
That said, while CHSRA initially toyed with the idea of High Speed Cargo, they never seriously pursued it. Their business plan calls for a new network dedicated to passenger operations, with no trains running in the middle of the night.
adirondacker12800 Reply:
July 7th, 2010 at 5:44 pm
The brisk overnight business is small share of FedEx or UPS freight. Much of the brisk business never sees the inside of an airplane, it moves by truck. Add the transhipping at either end – unless you want to build rail to the UPS and FedEx distribution hubs or move the hubs to rails – even fast trains take too long.
O/T: The City of Mountain View has published its draft response to CHSRA’s Alignment Alternatives in the SF peninsula.
Highlights:
- cautiously positive on the HSR project
- preference for trench over fully elevated or at-grade, at CHSRA’s expense
- at-grade ok south of Castro
- need for deep trench under Permanente Creek questioned
- 1% transition gradient limit questioned
- preserve traffic lanes on Central Expy and W Evelyn
- preserve Castro/Moffett crossing
- preserve or expand VTA light rail and other connecting transit
- if a tunnel is being considered in Palo Alto, it should also be in Mtn View (for “equity”)
- no formal discussions with neighboring cities or the county, CHSRA not driving this
- lack of details on noise, vibration, traffic impacts, construction impacts
- lack of details on process/criteria for selecting mid-peninsula HSR station
Not highlighted:
- rail corridor between 85 and 237 not wide enough for 4 tracks side-by-side, never mind 5 (or 6)
- trench impacts on Stevens Creek, especially if Caltrain station not moved to far side of Castro
rafael Reply:
July 5th, 2010 at 3:03 am
Redwood City has published its own draft response.
Highlights:
- trench/stacked tunnel preferred
- impacts on two creeks + Hetch Hetchy water pipe need to be clarified
- connection to Port of RWC must be preserved, move junction south
- preserve Dumbarton wye
- only FRA tracks at grade in south RWC, HSR tracks should be below grade
- minimize property takings (regardless of cost to taxpayer)
I’d classify this as a “Dear Santa” letter, much like Mtn View’s reply. There’s no way to preserve connectivity to both the spur to the mighty Port of RWC and to the Dumbarton spur if the FRA rails are fully below grade at Chestnut St just 500ft further north. With the transition gradient limited to 1%, something’s got to give. Assuming CHSRA even entertains the notion of trenching in RWC, the FRA tracks need to be (almost) at grade at Chestnut St. The crossings at Main, Maple and probably Jefferson would then also need to become low overpasses (reverse split grade).
RWC did not consider the option of lowering both the freight spur and Dumbarton wye to preserve the lateral location of the junctions with the FRA-compliant main line. Perhaps even the city council recognizes the effort involved would bear little resemblance to the economic value of both the Port and future Dumbarton rail services.
spam?
Robert Cruickshank Reply:
July 5th, 2010 at 8:17 am
I caught it and deleted it just as you left this comment, apparently.
I can think of two possible explanations for Lowenthal’s statements and actions re HSR.
1. As Rafael said, he’s peeved that the Legislature doesn’t have control over the HSR bond funds. Or rather, he’s peeved that the Leg has no control over the project or the Authority, period. It’s in the nature of members of the Legislature to believe that they perform a crucially important job of safeguarding the public interest, so the fact that CHSRA operates outside of legislative control quite likely makes Lowenthal et al automatically suspicious of its motives and performance.
1(a). Add the fact the the members of the CHSRA and the former Executive Director have not been the most impressive or reliable spokespeople for the project, and I can easily picture Lowenthal’s suspicions and concerns spinning out of control.
1(a)(i) Fortunately, this may be a problem that Roelof Van Ark can solve.
2. My other theory is that Lowenthal is, like so many legislators, simply reflecting the advice that he gets from his staff.
2(b). The obvious follow on question would then be which staffers are we talking about and what’s motivating them?
Personally, I think it’s more #1 than #2, though once #1 gets rolling along any good staffer is going to do his or her best to support and advance the cause.
morris brown Reply:
July 5th, 2010 at 8:47 pm
Mike you are very badly informed. The legislature has complete control over HSR bond funds — read Prop 1A/AB-3034.
Rafael never said the legislature didn’t have control over the funds, because he knows full well they do. In fact Lowenthal made quite certain they had control over these funds.
Neither Rafael or Robert or any of the other pro-HSR advocates that frequent this blog and have read Prop 1A will dispute that fact. Your Paragraph 1 above is nonsense.
Robert Cruickshank Reply:
July 5th, 2010 at 9:17 pm
There’s a difference between “control over releasing the Prop 1A bond funds,” which is what you’re talking about, and “control over what the Prop 1A bond funds can be used for,” which is what I suspect Mike is talking about. It could be that Lowenthal would like greater legislative control over that rather large pot of money.
rafael Reply:
July 7th, 2010 at 3:34 pm
AB3034 explicitly gives the state legislature control over actual appropriations of prop 1A bonds in the context of the annual state budget process. The primary reason for that is that the state may or may not be willing – or able – to actually sell any general obligation bonds for HSR in a given year.
The legislation also includes a long list of criteria that CHSRA must meet in its applications for appropriations, including especially proof of non-state matching funds. That list was put in for a very simple reason: once dirt is turned, the cost of making changes goes up dramatically. There is also an inflation penalty as well as high opportunity costs if the project is delayed. Indeed, there’s a significant risk that year-of-expenditure federal grants would disappear or prove insufficient.
Sen. Lowenthal knows this full well and, he doesn’t want to be seen as the person who strangled this mega-project with legislative red tape. At the same time, as far as I can tell, he desperately wants to influence CHSRA’s priorities to ensure that as much of the prop 1A funds as possible is spent in Orange County. Politically, that means also prioritizing the SF peninsula.
Lowenthal appears to have little or no confidence in CHSRA’s ability to raise the balance of funds needed to complete the starter line. What he doesn’t appear to understand is that in the event the money runs out, re-purposing the portions of the line that do get built for regional passenger rail would actually be far from trivial, especially in SoCal. Granted, most of the issues could be dealt with by augmenting CHSRA’s technical specs to limit transition gradients, increase permissible axle loads, increase ventilation capacity in tunnels (if any), choosing a statewide standard for positive train control technology etc. However, afaik, Lowenthal hasn’t even sought the technical expertise of Caltrans’ Division of Rail or Metrolink to identify exactly what CHSRA’s technical specs for e.g. LA-Anaheim would need to look like to cover the mere possibility of having to re-purpose the investment.