This letter was originally sent to the Mendocino Council of Governments on August 22, 2025. Mendocino Railway President and CEO Robert Pinoli responds in the post below.
In past transportation plans the Mendocino Council of Governments (MCOG) included the Mendocino Railway (also know as the Skunk Train) as a rail transportation option for commuting and freight hauling within Mendocino County’s transportation planning portfolio. As MCOG prepares to update the County’s transportation plan, it is inappropriate to continue characterizing the Skunk train as a public transportation and/or freight hauling service for the following reasons.
The Skunk Train is not a transportation provider, it is a private out-and-back entertainment excursion train experience for tourists visiting Mendocino County. It is no more a form of transportation than a merry-go-round ride at the county fair or group boats offering a fishing & whale watching experience along the coast.
Unlike legitimate public rail transportation which provide the public with passenger and/or freight transportation between communities and cities, Mendocino Railway’s Skunk Train does neither.
Since the last update to the County transportation plan, Mendocino Railway’s Skunk Train services have been reviewed and assessed both by federal, state, and local agencies as well as by the courts. In each of these reviews and court proceedings, Mendocino Railway has failed to present a compelling case that it provides anything more than an excursion train entertainment experience for its customers.
The California Public Utilities Commission has repeatedly reviewed the Skunk Train’s operations and determined Mendocino Railway is an excursion train:
In 2022, the California Public Utilities Commission’s Assistant General Counsel clarified the Skunk Trains status as a regulated excursion train:
“The status of Mendocino Railway, has previously been determined by the Commission. In 1977, the California Western Railroad (CWRR) - which was the company operating the excursion service commonly known as the “Skunk Train” at the time - applied to the Commission for status to reduce its commuter passenger services. In the course of this proceeding, the Commission determined (in 1998) that CWRR did not constitute a public utility to the extent it provides excursion rail service, which constituted 90% of its overall business.”*
“The Commission is not aware of any changes to the excursion services provided by Mendocino Railway that would cause a change to its 1998 determination”*
Similarly, the Great Redwood Trail Agency petitioned the federal government to formally abandon the Skunk Train connection to the federal interstate rail system because the Skunk Train has not operated as a interstate passenger train or freight service for more than twenty years.
In its petition, the Agency clearly articulated why Mendocino Railway’s Skunk Train does not and can not provide passenger and freight transportation:
“No freight movements have originated on, terminated on, or otherwise traversed the MR Line since MR purchased it out of bankruptcy in 2004, and no shippers that have been served in the past on the MR Line have a current need for rail service.
Moreover, there are no reasonable prospect of future rail service needs along the MR Line. The MR Line has only been operated for intrastate tourist excursion rail service, called the “Skunk Train,” since its acquisition by MR in 2004.
And the MR Line itself is not even fully traversable from beginning to end due to a tunnel collapse. Moreover, the MR Line will require significant rehabilitation to bring it in line with FRA Class I track standards, (rehabilitation cost estimate is $31,598,000 for MR Line).”**
Likewise, the issue of Mendocino Railway’s status as an excursion train rather than a transportation provider has been adjudicated by the courts. In a 2023 ruling in a lawsuit over the inappropriate use of eminent domain authority by Mendocino Railway, Mendocino County Superior Court Justice Nadel, found Mendocino Railway unable to show sufficient evidence it provides freight service or provides meaningful passenger transportation service to meet the requirements of being a transportation public utility with eminent domain authority.
In explaining the decision, the court based its determination upon a series of undisputed relevant facts.***
• Mendocino Railway’s Articles of Incorporation do not reflect the intent to operate as a railroad.
• There was no designation of Mendocino Railway’s status by the (federal) Surface Transportation Board offered byMendocino Railway.
• In 2015, there was a landslide in “Tunnel No.1” preventing the train from running the full length of the line since that date. No transportation between Fort Bragg and Willits has occurred since the tunnel was closed.
• Mendocino Railway conceded that currently its main function is the operation of a popular excursion train know as the Skunk Train for sightseeing purposes on the line through the redwoods.
• The Skunk Train’s operation is limited to traveling from the Willits station west approximately 7.5 miles before turning around and traveling back to Willits. From Ff. Bragg, due to the tunnel collapse, the train can only travel east for 3.5 miles before it turns around and returns to Ft. Bragg.
• The excursion service generates ninety percent of Mendocino Railway’s income. The other ten percent of Mendocino Railway’s income is from leases and easement revenue.
In making its determination that Mendocino Railway is not a public utility, the court cited California Public Utilities Code section 229, which provides that a “railroad” includes every commercial, interurban, and other railway...owned, controlled, operated, or managed for the public use in the transportation of persons or property. The court further noted that Mendocino Railway did not dispute that “transportation” in the public utility context means “the taking up of persons or property at some point and putting them down at another.” The court also noted, round trip excursions do not qualify as “transportation” under Section 211 of the Public Utilities Code. Most importantly, Mendocino Railway conceded that the term “transportation” excludes excursion services for the purposes of being a public utility.****
The court’s ruling in the Mendocino Railway v John Meyer case is important to MCOG in deciding whether to include or exclude the railway in the county transportation plan. Since the law dictates that excursion services are not transportation, inclusion of such excursion services in a transportation plan is inappropriate. The court’s ruling demonstrates clearly, Mendocino Railway does not qualify in any significant way as a transportation service.
The purpose of the County plan is to provide the county’s best assessment of its transportation needs. Federal and State transportation partners use the plan to assist them planning transportation efforts they hope to accomplish within the county.
It is important that the plan reflects true “transportation” needs. Inclusion of efforts or initiatives that are not transportation, undermine the integrity of the plan and hinder Federal and State partners in their deliberations about how to assist county transportation agencies.
Lastly, MCOG should keep in mind that the purpose of the county transportation plan is to assist public agencies setting priorities for the use of public resources to successfully attain transportation outcomes that further the public interest. In setting priorities, planners must consider the economic viability of transportation initiatives incorporated in transportation plans.
A 2023 assessment of the economic market feasibility of rail service in Mendocino County raised serious questions about the financial viability of Mendocino Railway (or any other rail company) to provide rail transportation service in the county. The assessment prepared by Marie Jones Consulting provided significant evidence that the costs of operating city to city rail service in Mendocino County exceed potential revenues. Further, the assessment determined that truck freight services were more cost effective and provided better service than any possible rail freight service could provide between Fort Bragg, Willits and Cloverdale.
The assessment highlighted several realities that make rail economically un-feasible as a transportation option in Mendocino County:
• The estimated capital investment costs of fully restoring the Fort Bragg to Willits rail line are more than $30 million. Additionally, the estimated on-going annual operation costs are approximately $2.5 million. Total annual estimated rail costs would be over $5.7 million per year.
• The estimated capital investment costs of fully restoring the Willits to Cloverdale rail line are more than $56 million. Additionally, the estimated on-going annual operation costs are approximately $5 million. Total annual estimated rail costs would be over $11 million per year.
• The cost of hauling freight by rail is not competitive compared to the cost of hauling by truck. The cost to transport freight by rail (assuming rail service was available) from Coverdale to Willits would be $458 per ton by rail, vs $29 per ton by truck.
The cost to transport freight by rail between Willits and Fort Bragg would be $608 per ton compared to $38 per ton by truck.*****
• Similarly, there is no evidence that restoring train service between the cities of Fort Bragg, Willits, and Cloverdale would result in sufficient rail passenger and/or freight hauling revenues to offset the full costs of restoring the lines to service.
• In Mendocino County, trucks and autos are more efficient than rail for transporting people and freight in terms of time as well as cost. For example, the average drive time by auto or truck between Coverdale and Fort Bragg is 1 hour and 50 minutes, compared to an estimated 10 hours by rail. The average drive time from Fort Bragg to Willits is 50 minutes compared to an estimated 6 hours by rail.******
• Transportation by auto and truck allows consumers to schedule transportation around their needs and schedule. Rail transportation is scheduled around the needs of the railway to manage its locomotives & rail-cars in order to balance demands from passengers and freight haulers.
• Further, autos and trucks can use alternate routes when roads are closed due to weather or land slides, all rail service is halted when rail tracks are closed due to weather or land slides. Auto and trucks can use roads 24/7 to transport people and freight, trains operate on fixed schedules or when demand is sufficient to justify the costs of a train trip.
• Demand for rail passenger/freight service between cities is entirely theoretical, since neither the Fort Bragg to Willits or the Willits to Cloverdale line are presently in a condition that would allow passenger/freight hauling by rail. Currently, all passenger and freight needs between the communities of Fort Bragg, Willits and Cloverdale are being met by autos and trucks.
In summation, the Mendocino County Regional Transportation Plan and Active Transportation Plan (RTP/ATP) is intended to be a long-range planning document covering a 20-year time span, which includes short and long range transportation projects across all modes of transportation, including motorized, non-motorized, and public transit. It promotes a safe and efficient transportation system, and establishes regional goals that support mobility, economic, and health aims of the region.
As the facts previously cited show, Mendocino County has not had a functioning rail service providing community to community passenger or freight transportation for more than a decade, and no functioning rail connectivity to the interstate system for more than two decades.
Its time to recognize those facts and amend the County’s transportation planning to reflect the realities. Rail passenger and freight transportation is not cost competitive compared to auto and truck transportation. Federal and state goals are not aligned with reestablishing interstate or intrastate rail transportation in Mendocino County. Mendocino Railway, the sole remaining train line operating in the county, functions as an out and back excursion and entertainment train serving the tourist industry. For all these reasons, rail is no longer a viable component of the Mendocino RTP/ATP plan.
Rather, if included in the RTP/ATP, Mendocino Railway’s excursion operations should be deemed part of the multi-modal planning like the Coastal Trail and the Great Redwood Regional Trail, which it most closely resembles.
Sincerely,
Peter McNamee
Fort Bragg, California
Citations
*Letter to Michael Hart, CEO Sierra Railroad Company, from Jonathan C. Kotzot, Assistant 1 General Counsel, Legal Division, Public Utilities Commission August 12, 2022
**Great Redwood Trail Agency - Adverse Abandonment - Mendocino Railway in Mendocino County, California Surface Transportation Board Docket No. AB-1305 (Sub-No. 1)
***Decision After Trial, April 19, 2023, Mendocino Railway v John Meyer Case # SCUK- 4 CVED-2020-74939
****City of St. Helena v Public Utilities Com (2004) 119 Cal. App. 4th 793,902 (Quoting Golden Date Scenic S.S. Lines, Inc. v Public Utilities Com. (1962) 57 Cal. 2d 373
*****Mendocino railway’s advertises a cost of $33 per ton for hauling freight, but according to the cost assessment prepared by Marie Jones Consulting, that is “a fiction” since the actual amount to recover all capitalize rail costs and operating expenses is $608 per ton.
******The assessment estimated rail transportation times based on national rail industry operational standards assuming the rail lines between Fort Bragg, Willits and Coverdale were renovated to federal and state rail requirement standards.