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Last ditch attempt to save LVRC
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Author:  Bob Yarger [ Mon Jun 14, 2004 2:09 pm ]
Post subject:  Last ditch attempt to save LVRC
Saw this today on the NERAIL list. It is an attempt to stop the destruction of Vermont's Lamoille Valley Road, the 98-mile former St. Johnsbury & Lamoille County (also known by several other names). The person mounting this campaign is a local person there:

To all Vermonters interested in saving the Lamoille Valley Railroad, please
read the following, and if possible, please write a letter to the Governor and
the Secretary of Transportation.

There may be just one last chance to stop the State of Vermont from tearing
up the track of the Lamoille Valley Railroad, which is planned to occur in the
next few weeks.

The only possible way to stop the imminent scrapping of the Lamoille Valley
(St.J&LC) railroad will be for enough people to write, phone and e-mail the
Governor, the Vermont Agency of Transportation (VTrans, formerly "VAOT"), and
probably the press as well, concerning specific false information the state's
attorneys had presented the Federal Surface Transportation Board (the STB)
earlier in the year. This is actually an ethics issue, directly involving the Agency
of Transportation, and it is very real.

It is obvious that the politicians don't really care at all about this
railroad or any of the facts concerning it, but they do care about allegations of
misconduct and public scandals. And in this case, not one but eight specific
items of incorrect, false or misleading information were intentionally filed
before the STB earlier this year, by attorneys in Washington, DC, acting for the
State of Vermont and the Lamoille Valley Railroad Company (the LVRC). We have
to let the Governor, the Agency of Transportation, the Legislators and the
Vermont press know that this falsification of information to the Federal
Government has gone beyond the limit. We have to let them know that citizens or Vermont
are aware of exactly what has been done, are willing to take this information
to the media if necessary, and that we will not let them ignore this and that
we do not intend to just "go away." It is important to let them know that
this unethical tactic of a state agency intentionally providing false and
misleading information to the STB must be properly corrected, with the STB, before
any more of the track comes up.

I have been fighting this recent battle almost alone, and I really do need
any and everyone who cares about saving this railroad to help this one last
time. It is our only possible chance save this rail infrastructure, since in their
arrogance, the opponents of rail transportation have taken the unethical
tactics they used in the Vermont Legislature all the way to Washington. If you
care about this rail line, and if you care about fairness, please help now. And
please send this to all of your Vermont friends. If enough voices are raised,
we can still have an effect. The battle won't be over, but this could buy just
a little more time. And once it is established and out in the open that
incorrect facts have been used in the decision process all along, we will at least
have another shot at demanding a truly fair process.

The facts about what has happened, and what needs to be done right now, are
as follows:

As some of you may know, I still have a Petition to Reopen filed with the STB
in the LVRC abandonment proceeding. As far as I can determine, this filing is
still active and yet to be reconsidered by the Board. The attorneys acting
for LVRC (who are actually VTran's legal counsel in the abandonment proceeding)
had filed a reply to my Petition to Reopen, which attempts to use eight items
which can be proven to be false, incorrect and misleading in order to totally
and entirely strike my Petition to Reopen. If this is stricken, there is no
possible chance of changing the STB action, to force a real abandonment
proceeding that would let the facts about shipper demand and the real cessation of
service that happened come out. These eight items can be summarized as follows:

1 - LVRC states there is no record of shipper complaints - Untrue, complaints
made in 1996/1997 public testimony described denial of service, telephone
calls not answered and extremely poor service. Frey Quarry also publicly
complained of lack of service during same basic time frame.

2 - LVRC claims it made sincere effort to build freight business - Blatantly
Untrue, as the Stone Consulting report had surveyed the potential shippers and
found no marketing effort or shipper contacts from Hardwick all the way west,
during LVRC's entire tenure on the line.

3 - LVRC claims last freight traffic was in 1989, in an effort to further
justify "exempt" type abandonment proceeding - Untrue, Frey Quarry on eastern end
of line had shipped in 1995, just before floods, as was reported in the press
at the time.

4 - LVRC claims/implies that MIT Report of 1997 concluded single highest and
best use was conversion to recreation trail - Untrue, MIT report recommended
rail use be given a chance in the short, medium and long term, and only if not
successful then recommended conversion of portions to trail. The MIT report
had also specifically recommended against snowmobile/mechanized use on
residential sections of the right of way.

5 - LVRC claims shipper requests for service is only "speculation" and
"alleged potential" interest - Untrue, shipper statements of interest were formally
submitted to VTrans in response to an official "Request for Proposal"
solicitation, and were then independently verified in Stone Consulting report, which
was also accepted by the internal Vermont Joint Fiscal Office audit report.

6 - LVRC strongly implies that removal of two bridges, totally isolating a
known shipper, was related to flood damage - Untrue, bridges were removed for
highway safety reasons, there was no flood damage to these structures. VTrans
had even acknowledged these bridge removals were not proper (since railroad was
not legally abandoned) at the time, and promised to replace if rail operation
were to be resumed. Other solutions to highway safety concerns were not tried.

7 - LVRC claims that track and grade crossings in West Danville were removed
for safety reasons - Untrue, as these two crossings were inspected by E&K
Consultants several months earlier and found to be in Good and Very Good
condition.

8 - LVRC claims no shipper interest in rail service and further
claims/implies LVRC was fully prepared and able to fulfill its common carrier obligation to
provide rail service upon "reasonable" request - Totally Untrue, as continued
intentional dismantling and damage to rail line (paved over crossings,
removed bridges, obstructions to track, and removal of track and engine facilities)
effectively pre-abandoned the rail line. Shippers actually did indicate that
they desired service, and LVRC was totally unable or unwilling to provide any
rail service. Also, Interim Agreement between LVRC and VTrans specifically
indicated that no actual rail service was either expected or required.

My Petition to Reopen was intended to provide the STB facts that had been
developed in State of Vermont studies and reports, which show that shippers had
indicated in formal submittals to VTrans a desire to receive rail service in
2001, which LVRC and VTrans had made no effort to provide, expending no effort
to maintain/repair while continuing to further damage the rail infrastructure,
and making it virtually impossible to ever provide rail service again (an
improper impediment to rail service and illegal embargo), which actually
represents an illegal cessation of rail service. All of these documents (including
source documents that were also submitted) are totally in the public record, and
available on the STB Web Site. My Petition to Reopen is listed as STB Document
#210098, and the reply from the attorneys for LVRC/VTrans is listed as STB
Document #210064, both available on the STB "filings" page; see also other
letters and responses. Once on the STB Web Site (www.stb.dot.gov) look for the
filings section and search under Lamoille Valley Railroad, and you can find
everything that has been filed in this abandonment proceeding. You can also find this
material using the Docket Number for the LVRC abandonment proceeding in a
search, which is AB-444 (Sub-No. 1X).

On April 20, 2004, I had written Secretary of Transportation McDonald a
formal complaint, and request for action, against the LVRC (in whose name the
state's legal counsel had acted) for the intentional presentation of false
information to the Surface Transportation Board. A copy of this with a cover letter
was sent to the Governor on April 23. In addition to providing detailed point by
point cross references and copies of all source documents providing the facts
to prove my statements, I also had requested the Agency of Transportation to
take immediate action to file an appropriate correction before the STB. Copies
were sent to the Governor (with the cover letter), and to both the House and
Senate Transportation Committees of the Legislature (then still in session),
to the 12 shippers that had expressed an interest in rail service in 2001, and
to others. Secretary McDonald wrote back on April 27 that (quite predictably)
the Agency of Transportation had no intention of responding to my complaint
(apparently being "misunderstood" as a request for an inquiry, which it was
not), because they say I am a "litigant" before the STB, and explaining that
VTrans is now only following the direction of the Legislature. My feeling is that
if VTrans will not accept my complaint, there are thousands of other people in
the State of Vermont who are not "litigants" in any way, who also know what
has happened on this railroad, and can certainly take exactly the same
complaints to the Secretary, especially since all of this information is available to
everyone is on the STB Web Site. I responded to the Secretary on May 14, 2004,
reiterating the earlier discussions and further explaining the complaint but
have yet to receive another response from her. I finally also received an
answer from the Governor on May 28, apparently responding to his copy of the
original April 20 complaint, which only reiterated the earlier letter from the
Secretary of Transportation. I had responded to the Governor on June 8, 2004.

As information, I have attached/uploaded an Adobe PDF file containing all of
these formal complaint and response letters to the Secretary of
Transportation, the letters to the Governor, and the responses that I had received to my
correspondence.

In each of my letters of complaint regarding this issue to the Secretary of
Transportation and the Governor, I have continued to request four major things;
First, that VTrans make an appropriate filing before the STB to correct all
misinformation that had been previously submitted at the Federal level by the
state's attorneys; Second, that any of this same information that had been
provided in the local decision making process be similarly corrected and the
situation explained to the appropriate organizations for proper reconsideration;
Third, that until the misinformation is corrected and acted upon and/or STB
returns a final decision, all activity to tear up the railroad be halted; and
Fourth (which is directly related to the second item, above), that owing to the
same misinformation having previously been provided locally (and the entire
decision therefore compromised), that based on corrected information
reconsideration of the abandonment decision also be made at the state and local level.
These requests are based on the fact that a fair decision regarding the railroad
should certainly have been made, but could not have been made, with the
intentionally provided false and inaccurate information. Falsification of information
to the Federal government done with the knowledge and cooperation of a State
of Vermont agency is highly unethical behavior and something that all
Vermonters should oppose. In addition, the Legislature certainly expected a fair
process before the Federal regulatory Board, only directing "railbanking" of those
portions of the railroad approved by the STB for abandonment (with the im
plicit understanding that in upholding Federal law, and in the protection of the
public interest, STB might not allow complete abandonment).

Right now, knowing that the Agency of Transportation has participated in
filing false information with the STB, it is most important to find a way to stop
the actual abandonment of track (which, as you know, they are moving forward
to accomplish in this construction season) pending either a final STB
determination in a reopened proceeding, or reconsideration of the corrected facts
locally, or alternatively, the findings of an independent internal Vermont ethics
investigation of VTran's questionable actions concerning the entire rail
abandonment decision process.

In addition, proper correction of misinformation presented to the STB would
add a VTrans Petition to Reopen filing to mine, to at least force a reopening
of the present truly illegitimate "exempt" (also referred to as "instant")
abandonment proceeding. More importantly, once the public record shows this
blatant falsification, the entire previous process must be properly challenged,
since it was based on much of the same false information, and it's legitimacy
strongly questioned. Of course, none of this will matter if they get away with
tearing up the rails in the next few months.

While I do not like to suggest specific responses to others for sending of
letters or e-mails to the Governor or the Secretary of Transportation, the
opponents of this railroad had previously organized their own "canned" letter
writing campaigns to spread much the same kind of misinformation as has been
recently sent to the STB to many of the decision makers. In this they had apparently
succeeded, blinding the Legislature, state agencies and planning commissions
to LVRC's prior scuttling of the freight business, the fact that there was
verified demand for rail service, and even that continuing rail service would
cost much less than trail conversion. For this reason, in this case and since
this is the last and only chance this railroad will have, I have offered several
suggested letters below.

I would urge those who want to write the Governor and Secretary of
Transportation not to just copy these letter examples exactly as they are, but to look
at the actual STB filing documents as well as my formal complaint letters, and
to review the actual supporting studys/reports that are the proof what has
really happened here. Please change, add, embellish and expand upon these
suggested letters. Above all, please let the Governor and the Agency of
Transportation know that they must take appropriate action to ensure a fair decision
concerning this rail line, that is fully consistent with the intent of the Vermont
Legislature, and which can only be accomplished by properly correcting all
misinformation that was supplied to the Federal STB (as well as all other prior
decision makers), and to immediately suspend all activity to remove track on the
rail line until updated decisions based on the corrected and accurate facts
can be made.

For additional information, the State of Vermont reports that provided the
supporting facts from the studies made, and had actually made recommendations in
favor of keeping rail service, can also be of help if you write. These
documents, that had been done either for or by the state itself or regional planning
commissions, are summarized and listed below:

The MIT "Highest And Best Use" Report of 1997 (also called the Martland
Report) - This was not really pro-rail, and had just accepted the LVRC's word that
it had tried hard to find rail traffic (it didn't, as per SC&D report, below),
but nevertheless recommended that rail service first be given a chance, in
the short, medium and long term; only if rail service was found not to be
successful, and only then, had the report recommended trail conversion.
Interestingly, the MIT Report had clearly recommended against snowmobile/mechanized use
for the right of way where it passed through residential areas (this fact is
totally ignored today). This report should have been updated once it was learned
LVRC had made no effort to seek rail traffic, and especially after shippers
were identified that wanted rail service, but never was. In spite of the fact it
actually recommended giving rail a chance, the MIT Report is still cited by
the Lamoille County Planning Commission (LCPC) as having recommended trail
conversion, with no mention of its recommendation against snowmobile use for
residential locations.

The Stone Consulting and Design (SC&D) Report of October 2001 - This report
found that LVRC had made no effort in its entire tenure on the line to market
or develop rail traffic, which was determined by interviewing all of the
prospective shippers identified in the Vermont Rail Link proposal that was made in
early 2001 to operate the rail line. The SC&D Report verified that there was a
real demand for rail service (generally on the western end of the line), and
that there was a latent traffic level to be realized of from 750 to 1000 rail
carloads per year even without any new marketing activity. Even more
importantly, this report predicted that the proposed freight and tourist rail operation
would break even in three years, and therefore not require an ongoing
operating subsidy from the State of Vermont. The report acknowledged that some form of
government help will be needed to repair the washout damage to the line, but
that this would be required for any use of the right of way. This will
definitely be true, and it should be noted, no one right now is talking about how
much money the trail conversion is expected to cost. You can be sure that once
the rails come up, we will learn how much more expensive than rail this will
really will be; once it is to late to save the railroad.

The Vermont Joint Fiscal Office (JFO) Audit Report - This audit report
analyzed the Vermont Rail Link proposal, and generally accepted the findings of the
SC&D report as to projected performance of the proposed rail operation. While
JFO accepted that the rail operation would break even, it pointed out that
maintenance of the right of way would still require some government assistance
for some time, but that the overall benefits of rail transportation to the
region might still be justified for such a publicly owned facility. It should be
noted, this is no different from other Vermont owned rail infrastructure, some
of which also requires an ongoing operating subsidy, which the proposed Vermont
Rail Link operation was not expected to need. This report is also important
in that it presented relative costs for rail and trail use of the line, and the
lowest cost by far was to restore rail. Basically, resumption of rail service
Swanton to Morrisville was $4.5 million (the first phase of the Vermont rail
Link Proposal, mostly washout repairs), while a VTrans standard width trail
end to end was projected at $61.1 million, only reduced to $23.1 million by
allowing a nonstandard narrow width trail. The above rail cost estimates were from
the Vermont Rail Link proposal, as reviewed and verified by independent
Professional Engineers qualified in railroad construction.

This sums up the basic information in the public record from State of Vermont
reports. I can supply PDF files of all documents; please ask. Just E-mail me
at TimPhe@aol.com if you require copies.

In any event, I hope you can write a letter or two if at all possible.
Anything you can write may help stop the planned senseless destruction of the
Lamoille Valley railroad. This truly is the last chance. Addresses and Proposed text
for letters follow.

Thank you in advance for anything you, or any of your friends and neighbors,
are able to do to help. Please give me any feedback on responses you may
receive to your letters, especially if any of the responses are also based on false
information known to be false.

Sincerely,

Tim Phelps
East Hardwick, Vermont
TimPhe@aol.com
802-472-2223

Addresses:

Governor Jim Douglas
109 State Street, The Pavilion
Montpelier, VT 05609-0101

Patricia A. McDonald, Secretary of Transportation,
Vermont Agency of Transportation, Headquarters,
1 National Life Drive, Drawer 33
Montpelier, VT 05633-0001

Separate Letters should be sent to the Governor and to the Secretary of
Transportation.

Letter Option 1, concerning LVRC claiming to be ready to provide rail service
upon request:

Dear Governor Douglas,
Dear Secretary McDonald,

It has come to my attention that a complaint was recently filed with the
Agency of Transportation regarding eight items of false information that were
provided to the Federal Surface Transportation Board in the name of the Lamoille
Valley Railroad Company by the state's legal counsel handling the abandonment
proceeding for this rail line. This concerns filings before the Surface
Transportation Board, STB document #210064, and possibly others, that I have recently
downloaded from the Surface Transportation Board Web Site. I totally agree
that this Surface Transportation Board filing contains significant
misinformation, and I believe it is totally improper for the Agency of Transportation to
support or allow incorrect information being sent to the Surface Transportation
Board, and that this must be corrected.

I am familiar with the recent situation on the Lamoille Valley Railroad, and
the fact that Vermont shippers had requested rail service along with the
Vermont Rail Link proposal to operate this railroad back in 2001, after the earlier
rail operator had refused to renew the original lease, and had made it known
that it had no interest in operating the railroad or serving these shippers.
Since that time, from approximately 1997, there was no way for any shipper to
get rail service on this line, and for this reason, no way for any rail traffic
to be handled on this railroad. And that is also why a search was made for a
new operator, since it was obvious that the state was not requiring the first
operator to perform any maintenance or rail service. Claims that rail service
could be provided are ridiculous, as all of us that regularly observed this
rail line know. We had all watched as the first operator, along with VTrans,
slowly made it impossible to operate any trains on the railroad, doing things
like totally paving over all of the highway crossings, removing track at some of
these crossings, taking out at least two railroad bridges, and removing the
engine servicing facilities at Morrisville. I also have the understanding that
the present agreement between the railroad operator and the state does not even
require the railroad operator to run trains. For this reason, I believe that
the claims which have been made by the state's legal counsel in STB filing
document #210064, that allege the rail operator was prepared provide rail service
after a reasonable request, are completely false and incorrect. I am not sure
why this railroad was allowed to be dismantled before Federal permission was
received to abandon it, and I strongly believe that this was not proper
procedure, and that this probably was actually an illegal discontinuance of the rail
service. For this reason, I am writing this letter as an additional complaint
against the Lamoille Valley Railroad Company, and/or the State of Vermont's
attorneys representing it, for presenting false information about the
availability of rail freight service on the Lamoille Valley railroad since 1997.

It has also come to my attention that the Agency of Transportation has taken
no action to correct any of the improper information that was given to the
Federal Surface Transportation Board. I believe this is wrong, and that any false
information that the Agency of Transportation is now aware had been
improperly sent to the Surface Transportation Board must immediately be corrected.
Also, I believe all activity to abandon the rail line this coming summer should be
suspended immediately, until the corrected information is provided all
concerned and can be reviewed for an updated decision in both Washington and
Vermont.

I feel the falsifying information to the Federal government is a serious
problem, especially if the Agency of Transportation has had knowledge of these
Surface Transportation Board filings. I request that you take every possible
action to properly correct this situation, to have all false information replaced,
and to stop any work to tear up track on this rail line until decisions based
upon correct information can be made.

Very Truly Yours,

xxxxxxxxxxxxxxxxxxxxx

Letter Option 2, about failure of LVRC, about LVRC failure to market service,
and verified traffic levels:

Dear Governor Douglas,
Dear Secretary McDonald,

I am writing about the State of Vermont's plan to abandon the Lamoille Valley
Railroad from St. Johnsbury to Swanton, which had required a decision
concerning the rail line by the Federal Surface Transportation Board, and especially
about incorrect information that attorneys working for the Agency of
Transportation have sent to the Surface Transportation Board concerning this railroad.
I have seen this information in an official document numbered 210064 that I
have recently downloaded from the Surface Transportation Board's Internet web
site. There are several things contained in this document that I also know are
incorrect, that Vermonters living along this railroad that have followed recent
events would know about, and which the attorneys have not described
correctly. The Agency of Transportation should have all of the facts about this
railroad, and should be able to provide these attorneys accurate information.

I have been told that a complaint has already made to the Agency of
Transportation concerning false information being sent to the Surface Transportation
Board concerning the abandonment of this railroad. I also agree that document
#210064 contains information about this railroad that is not correct.

The attorneys working for the Agency of Transportation and the Lamoille
Valley railroad company say that the railroad had made a real effort to build
freight business on the railroad, but I know this is not what really happened. I
had asked at the Lamoille County Planning Commission about the railroad and was
sent a report made by a consultant named Stone Consulting & Design in October
2001. This report actually said that the railroad company had made no effort
to contact any of the shippers at all, for as long as the railroad company had
been responsible to operate this railroad line for the state, and that this
was really why there was no rail traffic. It also said that there were a number
of shippers that wanted rail service, and the report said these shippers had
all been contacted, and it projected that there would be up to 1000 railroad
cars a year of freight business right away, with more when a real marketing
effort was done in the future. I was surprised to find that this report actually
said that another engine would be needed to handle the freight business, since
the consultants were surprised that there was more interest in freight service
than they originally thought. Also this report said that the railroad would
make money in a few years, although that some state or federal money might be
needed to fix the parts of the line that had washed out in the 1990s, but that
this damage would have to be fixed by someone anyway, even if the line was
made into a recreation trail. From this report, and what was said at the public
meetings on the railroad, I know that what the state's attorneys have said to
the Surface Transportation Board is not correct.

I remember that at one of the railroad meetings in 1996 or 1997 a shipper
told of being refused freight service by the railroad, which was also reported in
the newspaper article about this meeting. Another shipper said he had called
the railroad about service, but could not get anyone to answer questions, and
he would be promised a phone call back, but the no one ever returned these
calls. Another shipper had talked about very poor service from the railroad
company shipping coal, where he could not get information from the railroad on his
shipment.

The attorneys working for the Agency of Transportation and the Lamoille
Valley railroad company also say in document #210064 that they think the shipper
requests for service that have been mentioned are only speculation and some kind
of alleged potential interest in freight service. This is more information
about the Lamoille Valley railroad that is not correct, and should not be given
to the Surface Transportation Board. The report I have mentioned from Stone
Consulting & Design checked out shippers that a new railroad named Vermont Rail
Link had discovered, so that and were included in a proposal to the Agency of
Transportation. This process does not look like it was speculation. The Stone
Consulting report confirmed that the shippers Vermont Rail Link had located
actually wanted rail service, and said that there was even more interest in
shipping on the railroad than before, so that these shippers must have been real.
The report was made after interviews with the shippers, so that it is not
right to say this was alleged potential interest, since the shippers turned out to
be really interested in having railroad service.

I do not understand why the Agency of Transportation allowed all of this to
happen in the 1990s, since this railroad company was supposed to be operating
the line to serve the shippers and the people of Vermont. The operator of the
railroad should have been told to properly operate the rail line for the state.
Otherwise, the operator should have been removed for failing to comply with
the contract with the state to run the railroad, and a new operator should have
been brought in. Although this was talked about, somehow it wasn't done.

And I do not understand why the Agency of Transportation would allow
incorrect facts about shippers wanting rail service to be sent to the Surface
Transportation Board by its attorneys for the railroad company. The Agency of
Transportation must know all of the facts about this rail line, especially the
information in the reports that the State of Vermont had made, so that the attorneys
working for the state should not have provided the Federal Government with
incorrect facts. I do not see how the Surface Transportation Board could make a
good decision if it has been given the wrong information.

With this letter, I want to also make a complaint that false information was
sent to the Surface Transportation Board by attorneys working for the Vermont
Agency of Transportation. I have looked at Surface Transportation Board
document #210064, and I believe that this contains information concerning the
abandonment of the Lamoille Valley railroad does not agree with the public testimony
at meetings, or studies made of the railroad for the State of Vermont. I also
believe it is not right for attorneys working for the state to supply
incorrect information to the Federal government.

I believe that all of the false information sent to the Surface
Transportation Board has to be corrected. Also, I believe that none of the Lamoille Valley
railroad track should be removed until this situation is completely corrected,
so that the Surface Transportation Board can make a fair decision about rail
service to the shippers that want it on this line.

Thank You,

xxxxxxxxxxxxxxxxxxxxxxxxxx

Letter Option 3, concerning MIT Report actually recommending to give rail
operation a chance, and recommending no snowmobile/mechanized trail for
residential areas:

BECAUSE OF EMAIL TEXT LENGTH LIMITS
FOR THIS OPTIONAL LETTER FORMAT SEE ATTACHED PDF

Thanks for any help you can give to help save the Lamoille Valley Railroad.



http://mywebpages.comcast.net/mikemcnh/flatcar/lvrc.html
ryarger@rypn.org
Author:  randygustafson@stoneconsu [ Wed Jun 16, 2004 11:04 pm ]
Post subject:  Re: Last ditch attempt to save LVRC
As our report is being referenced quite a bit in this message, I think it's appropriate to comment.

We were hired by the Vermont Joint Fiscal office to review the response to the proposal for continued operations of railroad. I'd been up to the line before while it was still being operated back about 1993.

I did the verification phone calls to the potential shippers, and I have to confess I was very skeptical when I started. By the time I was done, I'd changed my position, at least on the Morrisville west operation with at least some potential just east of there on a seasonal basis. There were some genuinely interested potential customers at that time, and the tourist operation, while not lucrative, could be made at least break-even if it were operated in conjunction with some freight service to allocate overhead.

The Joint Fiscal office accepted our report and did follow-up questions after it was submitted.

There was certainly no guarantee of success, but I've seen shortlines succeed and survive on a whole lot less than this. I have no information on the in-depth political/trail process subsequent to this, I just wanted to state here that the references to the independent analysis by SC&D report are generally accurate. We did not, however, feel that it was realistic to reopen the entire line, and recommended railbanking the eastern track similar to the George Michelson trail outside Deadwood, SD (leave the rail in place and gravel level to allow interim trail usage without rail removal - just in case something would emerge for cross-Vermont traffic in the coming years.)
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