WHITE PAPER

How the CSI Report Analyzed the Wrong Train Project

Measuring the Colorado Connector against the right peers, the right costs and the right question

A response to the Common Sense Institute’s “Ballot Issue 7A: Proposed Tax for Front Range Rail” (October 8, 2026)

Greater Denver Transit

October 14, 2026

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CSI’s analysis is not analyzing the project on the ballot. CoCo is not FasTracks, and it is not RTD. It is a practical intercity passenger rail service built on existing infrastructure, financed in phases, and scaled up as demand grows, which is exactly the model its nine peers have proven across the country. Measured against the right projects, CoCo is a sound investment for the Front Range.

Executive Summary

The Common Sense Institute set out to test the cost and ridership of the Colorado Connector (CoCo). Instead, it tested a different project. CSI benchmarks CoCo’s costs against RTD FasTracks, an urban transit system built largely from scratch. It treats a conservative ridership forecast as a ceiling. It grades CoCo on whether it empties I-25, when CoCo is built to be an alternative to I-25. It counts the tax but never weighs what the tax buys. Voters trying to tell good rail projects from bad ones deserve the right comparison, and when CoCo is measured against the nine peer routes named in its own Delivery Plan (and against CSI’s own numbers) it holds up.

1. CSI Benchmarks CoCo Against FasTracks, a Project Built the Opposite Way

CSI’s cost case rests on FasTracks: approved in 2004, 78 of 119 planned miles built by 2024, at roughly $72 million per mile. But FasTracks and CoCo are close to opposites. FasTracks built new rail corridors from the ground up. CoCo runs on rail lines that already exist, using BNSF, Union Pacific and RTD infrastructure and adding targeted upgrades such as sidings, signals, crossovers and stations. That is how CoCo delivers rail service at a fraction of the cost:

• Starter Service: $332 million for about 69 operating miles (Denver Union Station to Fort Collins), or roughly $4.8 million per mile, about one-fifteenth of FasTracks’ per-mile cost.
• Full 20-year program: about $4.7 billion for roughly 190 miles, or about $24.7 million per mile, about one-third of FasTracks, even with every future phase included.

CSI also imports RTD’s post-pandemic ridership losses, rising administrative costs and assault counts as if they predict CoCo’s performance. CoCo is not an RTD service. Amtrak will be the initial operator, and it’s worth noting that Amtrak’s intercity ridership has risen every year post pandemic, and is now shattering pre-pandemic records each year, while transit within cities has struggled to recover. Post pandemic trends have made traveling between cities more attractive, not less.

An intercity train carries passengers bound for business meetings, medical appointments, events, family visits, recreation and (85% of surveyed riders described discretionary trips). Intercity peers also recover far more of their operating costs from fares than urban transit does. While western US urban transit covers only 4-9% of its operating costs from tickets, Amtrak Cascades covered 52.9% in 2024, the Downeaster covered 54% in FY2024, and California’s three state-supported routes historically recovered 50% to 70%. Judging an intercity overlay by an urban transit agency’s trends doesn’t help voters understand CoCo. It describes a different kind of project.

2. CSI Blurs What 7A Actually Buys, and When

CSI presents a headline capital figure without explaining the phasing behind it, and its own numbers drift: about $4.4 billion in its Key Findings and $4.7 billion in the body, with operating costs given as $55–80 million a year in one place and about $15 million in another. The Delivery Plan is clearer. The $4.7 billion is a 20-year, five-phase program, not a check written in 2027:

Table 1. Colorado Connector delivery phases. Source: Front Range Passenger Rail District, Colorado Connector Delivery Plan (July 2026).

The $580 million of debt authorization has one job: to deliver Phase 2 within five years of voter approval rather than waiting years to save up cash. It is repaid over time from the 0.333% sales tax. Later phases are added incrementally through roughly 2045.

CSI’s own analysis also confirms that 7A is a capital program, not an open-ended operating subsidy. CSI calculates that 7A revenue exceeds CoCo’s near-term operating needs by roughly 20 times. Fully Expanded Service costs $85–116 million a year to operate, and $30–36 million of that is already committed by CTIO, the Clean Transit Enterprise and RTD. The District’s share is $55–80 million, and this is in the most distant period where ridership easily exceeds 1 million riders per year, and is likely closer to 2 million per year based on peer services today.

3. The Right Comparison: The Nine Peer Routes, Using CSI’s Own Numbers

The Delivery Plan identifies nine peer services that share CoCo’s model: multiple daily round trips, intercity markets, and tracks owned or dispatched by Class I freight railroads. CSI uses the same nine routes, but only for two metrics. Here is the fuller picture:

Table 2. The Delivery Plan’s nine peer routes. * Seats filled and operating result are CSI’s figures. Miles and round trips are from the Delivery Plan’s peer table; ridership is from Amtrak’s FY2025 year-end fact sheet.

Read side by side, CSI’s own peer data undercuts its conclusions:

• Frequency. At full build, CoCo’s 10 northern round trips would rank third among these ten services, behind only Capitol Corridor and Pacific Surfliner, and ahead of every peer outside California.
• Demand. The plan’s forecast of about 3,500 daily trips (about 1.27 million a year) is the number CSI calls “low demand.” Yet it would place CoCo second among these services on today’s ridership, behind only Pacific Surfliner. It is a planning floor, not a ceiling. The 2020 Alternatives Analysis projected about 2.2 million annual riders for a faster, more frequent service.
• Seats filled. CSI dismisses peers because none fills more than 60% of its seats on average. But the two most frequent, most-ridden peers post among the lowest averages: Pacific Surfliner fills 27.6% while carrying more than 2 million riders a year, and Capitol Corridor fills 30%. Frequent corridor service with many short trips always shows lower all-day averages, because it runs trains when people need them, not only when every seat sells. CSI’s sub-15% estimate for CoCo comes from the same arithmetic, and it signals a frequent, flexible service rather than a failing one.
• Operating results. Unlike local transit agencies like RTD that only recover 4-9% of the operating cost from fares, the peer routes noted above recoup significantly more of their cost, ranging from 30% to 60%. Compared to local transit, intercity passenger trains recover significantly more of their operating cost. Transit agencies are not even directionally accurate to inform on the future cost recovery of CoCo.

CSI also notes that CoCo’s 4.75-million-person market is smaller than any peer’s. Those peer figures count entire endpoint metros: Chicago alone accounts for the bulk of the Hiawatha, Lincoln Service and Wolverine totals. Downeaster, serving a much smaller market in size outside of Boston, carried nearly 550,000 riders in FY2025.

4. A Double Standard: Rail Is Judged on Averages, Highways on the Peak

Highway projects are never dismissed because I-25 has spare capacity at 11 a.m. Both highways and rail are rightly planned around peak demand. Applying an all-day seat average to rail, and only to rail, is a modal double standard that is irresponsible.

The same goes for subsidy. CSI treats public support for trains as disqualifying, but every mode in Colorado is subsidized. More than $4.3 billion has gone into adjusting/expanding/maintaining Colorado’s two largest interstates since 2018. That is more than double the roughly $2.0 billion (Phases 1 and 2) it takes to run CoCo from Fort Collins to Pueblo, and congestion returned on the widened corridors.

CSI’s alternative is that the same money could widen I-25 by two lanes for 170 miles. That estimate is scaled from projects like the I-25 South Gap ($419 million for 18 rural miles, about $23 million per mile). Urban widening costs far more. Central 70 cost about $1.2 billion for roughly 10 miles. A widened highway also adds no travel option. When it fills, drivers have no alternative, and a train does not get stuck in that traffic.

5. CoCo Is an Alternative to I-25, Not a Fix for I-25

CSI grades CoCo on the wrong test. It measures the train by how much it would shrink driving on I-25 (20.5 million vehicle miles a year, under 0.3% of the corridor’s 6.9 billion), notes that most of those trips would happen outside rush hour, and calls the effect on commute times “uncertain.” But CoCo was never designed to make I-25 flow faster. It is designed to let Front Range travelers make the trip without I-25: a second, independent route between Fort Collins, Boulder, Denver, Colorado Springs and Pueblo that does not slow down when the highway does.

By CSI’s yardstick, every transportation investment fails. No single project fixes I-25, not even the widening CSI offers as its alternative. Added lanes fill back up as new trips appear, which is why congestion returned on the corridors Colorado has widened since 2018. Pacific Surfliner is not judged on whether it emptied I-5, and Capitol Corridor is not judged on whether it emptied I-80. They are valued because they move over one million people a year who no longer have to be on those highways. Nobody judges Bustang by whether it speeds up I-25, either, and its ridership has grown fivefold since 2021 because people want a way to make the trip without driving.

What a real alternative to I-25 is worth:

• A trip you can plan around. When a crash, a snowstorm on Monument Hill or a construction closure stops I-25, there is no parallel route of comparable speed. A train on its own schedule gives travelers a predictable trip time and gives the corridor redundancy it does not have today.
• A choice for people who can’t or would rather not drive. That includes college students in Fort Collins, Boulder, Colorado Springs and Pueblo, older residents who no longer want to drive long distances, households without a second car, and visitors arriving at Union Station.
• Time back. An hour on the train is an hour to work, read or rest. An hour behind the wheel on I-25 is not.
• Off-peak trips are the market, not a weakness. CSI treats CoCo’s off-peak ridership as a flaw. The Delivery Plan’s rider survey shows people plan to use CoCo for concerts and festivals (23%), visiting family and friends (19%), sporting events (17%) and outdoor recreation (17%). Those are the evening and weekend trips that today have no option but the car.

The need for that alternative is growing. The Denver Regional Council of Governments warns that by 2050, 2 p.m. traffic will look like today’s 5 p.m. rush, so the windows people now use to avoid traffic will disappear.

6. Freight Railroads Are Why CoCo Is Affordable, Not a Flaw

Every one of the nine peers runs over track owned or dispatched by Class I freight railroads. CoCo follows the same proven approach, and it is already further along than CSI acknowledges:

• A 25-year BNSF access term sheet for Denver–Fort Collins includes contractual passenger priority at designated times and on-time performance requirements.
• Both of the rail owners (BNSF and Union Pacific) hold non-voting seats on the Rail District board, and have advised on exactly which projects are needed to be built to introduce reliable passenger service.

The right question is not whether CoCo looks like a greenfield rail project. It doesn’t. The right question is whether Colorado can add reliable intercity passenger service to infrastructure that already exists, and nine peer routes show that it can.

7. CSI Ignores the Reasons to Build CoCo at All

For a purportedly neutral ballot analysis, CSI never weighs CoCo’s primary benefits. Its economic model counts the full tax as a drag on the economy but assigns no value to travel-time reliability, household transportation savings, housing or reduced driving. A model that cannot see benefits will always report a loss.

Environment and housing. The Southwest Energy Efficiency Project (SWEEP) studied the same ridership forecast CSI relies on (about 1.27 million annual trips) and reached a very different conclusion. CSI finds 20.5 million vehicle miles avoided per year and calls that trivial. SWEEP finds:

• 30.7 million vehicle miles traveled eliminated each year from riders switching from cars alone.
• About 233 million vehicle miles eliminated annually once the station-area development CoCo unlocks is included. Land-use effects are 6.6 times larger than mode shift alone, and CSI omits them entirely.
• More than 24,000 new homes within about a half-mile of CoCo stations by 2045, reducing sprawl and car dependence at the source.
• About 124,500 metric tons of greenhouse gas emissions avoided per year by 2045, the equivalent of taking 29,000 gas-powered cars off the road.
• Nearly $9,000 a year in transportation savings for households in walkable, transit-served communities, and about 2,396 acre-feet of water saved annually.

SWEEP describes these as a “reasonably optimistic” full-buildout scenario. Even its mode-shift figure alone exceeds CSI’s estimate by half, and CSI does not attempt the land-use analysis at all, which fundamentally misunderstands the point of rail investment.

8. A Word on Common Sense

There is an irony here worth savoring. An organization that named itself after common sense has concluded that running passenger trains between neighboring cities is a risky, unproven experiment. On six of the world’s seven continents, it is neither risky nor an experiment. It is simply how mid-to-large population centers connect.

Kenya runs the Madaraka Express between Nairobi and Mombasa. South Korea’s KTX ties Seoul to Busan. Morocco built Africa’s first high-speed line. Germany, a nation that treats the automobile as a minor branch of theology, invested unceasingly in expanding regional trains between almost every pair of cities worth connecting. Victoria, Australia, has spent heavily rebuilding regional rail to Geelong, Ballarat and Bendigo. Chile runs trains from Santiago south to Chillán, and Canada runs VIA Rail through the Québec City–Windsor corridor. These are rich countries and poor ones, vast and compact, many of them places where nearly every household owns a car. Each looked at the same question Colorado faces and reached the same answer.

Common sense in transportation, it turns out, is rather more common abroad. This global common sense can only be unrecognizable to the Common Sense Institute because of a strange ideological possession unique to North America where passenger trains are not recognized as the public services they are across the rest of the world, but framed as being poor for-profit enterprises when this is not their function. When places as different as Nairobi and Seoul agree on something, the burden of proof falls on the dissenter. CoCo is “unproven” only in a report that never looked past America’s borders for the proof.

Conclusion: The Bottom Line

Table 3. CSI’s claims against the right comparison.

CSI’s analysis is not analyzing the project on the ballot. CoCo is not FasTracks, and it is not RTD. It is a practical intercity passenger rail service built on existing infrastructure, financed in phases, and scaled up as demand grows, which is exactly the model its nine peers have proven across the country.

Sources

1. Common Sense Institute, “Ballot Issue 7A: Proposed Tax for Front Range Rail,” October 8, 2026. commonsenseinstituteus.org
2. Front Range Passenger Rail District, Colorado Connector Delivery Plan (draft, July 17, 2026): phases, costs, O&M, peer table (p. 59), BNSF term sheet. coloradoconnector.com
3. Amtrak, FY2025 Year-End Ridership Fact Sheet (November 2025). media.amtrak.com
4. Southwest Energy Efficiency Project, “Front Range Passenger Rail could deliver major transportation and environmental benefits,” August 24, 2026. swenergy.org
5. WSDOT, “Amtrak Cascades: 2025 Performance Data Report,” March 2026 (reports 2024 farebox recovery of 52.9%).
6. NNEPRA, “NNEPRA 101” presentation to Maine DOT PTAC, October 2024 (Downeaster FY24 cost recovery 54%).
7. Capitol Corridor JPA, FY 2025–26 & FY 2026–27 Annual Business Plan, draft of April 2025 (farebox recovery 61% in FY2019).
8. California Legislative Analyst’s Office, Overview of California’s State-Supported Intercity Rail Routes and Funding (2025).
9. CDOT, I-25 South Gap project page ($419M, 18 miles).
10. ENR, “Colorado Rail District Advances $4.7B Front Range Passenger Rail Delivery Plan,” July 2026.