13 April 2013

High Voltage Rule Making

25,000-volt alternating current overhead electrification, the worldwide standard for powering modern passenger trains as now planned for Caltrain and the statewide high-speed rail system, currently does not exist anywhere in California. Nor do any regulations exist to ensure its safe and reliable implementation. That's why the California High-Speed Rail Authority and its consultants have successfully petitioned the California Public Utilities Commission for a new regulatory framework to enable the use of 25 kV technology in California.

In concert with the CPUC, a committee of HSR technocrats has developed a proposed General Order to regulate important topics such as:
  • Performance requirements
  • Clearances and protection against electric shock
  • Grounding and bonding
  • Strength requirements
  • Safe working practices
  • Incident reporting
The rule-making proceeding can be found under CPUC docket number R1303009.  The proposed draft regulatory document (2.3 MB PDF, known as a "General Order" or GO) can be found under CPUC petition docket number P1210011.  A close reading of this proposed GO reveals two fundamental flaws that seem to have entirely escaped the authors:
  1. The draft GO proposes to regulate 25 kV overhead electrification specifically for the operation of high speed trains.  The authors commit a fundamental category error by treating 25 kV electrification as a technology that is unique to 200+ mph high-speed rail, which is flat out wrong.  25 kV electrification is a world-wide standard technology used for powering any type of train, from commuter to freight to intercity to high-speed rail.  Examples abound, even within the United States, and could someday find their way to California--let's say for example, the San Francisco peninsula.  California regulations should not preclude any of these other applications just because they were authored by and for the HSR project.  The GO should regulate 25 kV AC electrification as a general category for powering electric railroads, and treat the specific application to high-speed rail as a sub-category.  The draft document should be entirely re-structured, with HSR relegated to a chapter that covers only those special regulations that pertain solely to high-speed operations.
  2. The draft document does not read like a concise regulatory document, and instead includes numerous pages of technical guidelines and best practices quoted nearly verbatim from the CHSRA's own technical specifications.  Much of the draft is descriptive material that speaks of the HSR system in the future tense.  The authors seem to have made no effort to separate descriptive material and run-of-the-mill engineering requirements from the key regulatory (safety) requirements, and the result is an unorganized mess of a kitchen sink that reads as if a committee of technocrats had authored it.  Which they apparently did.
You might think that someone close to the matter would say something about these obvious flaws, but all that Caltrain could muster as a response (under P12100011) is this:
Based on our prior coordination with the CHSRA and discussions with California Public Utilities Commission (CPUC) staff, the following is our understanding:
  • The CHSRA Petition and proposed GO broadly describes the statewide high-speed rail system to include "shared use corridors"; 
  • The reference to "shared use corridors" would include the Caltrain corridor, which is in the SF to SJ segment of the CHSRA blended statewide system; 
  • The GO would potentially be applicable to the Caltrain electrification project, to be led by the PCJPB; and 
  • The Caltrain electrification project will require specific regulatory consideration of the effect of 25 kV ac power lines upon signal predictors for at-grade crossings, which may require JPB to seek its own GO or to request an amendment to the GO being proposed by CHSRA. 
In other words, Caltrain politely requests to be considered as part of the HSR system so that whatever (really, whatever!) regulations of 25 kV electrification, as drafted by the CHSRA and its consultants, can "potentially" become applicable to Caltrain's own electrification project.  They couldn't get any more passive than this.

It is becoming clear that our rail agencies and state regulators are falling all over themselves in their incompetence to craft a logical regulatory framework around a mature world-standard technology.


  1. Clem writes:
    The authors seem to have made no effort to separate descriptive material and run-of-the-mill engineering requirements from the key regulatory (safety) requirements, and the result is an unorganized mess of a kitchen sink that reads as if a committee of technocrats had authored it. Which they apparently did.

    Clem, if the GO had been written by *real* technocrats, it would be logically structured, and with a clear delineation between normative and non-normative text.

    What you describe is a document cut-and-pasted together by a bunch of political hacks.(Henry Alvarez, anyone?)

    At least your condemnation is addressed to almost the right people: the political appointees who are making a hash of it. (Much saner than blaming the contractors, who are only following the incentives the market gives them).

    IMHo, the people you should really critique is the political masters, who appoint polit9ical hacks to run multi-billion dollar engineering projects, with *no* actual in-house engineering competence. (CBOSS, all over again!)

    1. Correct. I would add that the political hacks don't really care whether the regulations will work for anyone else.

      Caltrain is basically saying "We can't be bothered to get this right." CHSRA is saying "We really can't be bothered to write regulations, but since CPUC won't write their own, we'll submit something."

      The key feature is that, AFAICT, there is nobody at CPUC with any in-house expertise in writing railroad regulation.

      If there was ANY person actually in charge of rail regulations at CPUC, that person would do what Alon says: copy the New Jersey (or Pennsylvania, or Connecticut, or Rhode Island, or Massachusetts, or New York, or Delaware, or Maryland, or DC) regulations.

      As far as I can tell, there isn't one.

      CPUC has a "Railroad Operations and Safety Branch". But, in the words of the website, "The CPUC employs federally certified inspectors to ensure that railroads comply with both federal and state railroad safety regulations." Most of these regulations are federal regulations, and the entire website is written from the point of view of enforcing federal laws.

      They also have some engineers who examine grade crossing safety. From the point of view of cars and trucks.

      It seems that CPUC doesn't actually have anyone who designs or creates railroad regulations. AT ALL. Not even a one-man department.

      Do you begin to see why CPUC railroad regulations are not updated? Ever? Except when there's an incident scandalous enough to cause the Commission members to intervene directly?

      The most recent train-related "general order" is the "no cellphones while driving trains" order. The one before that is meaningless gobbledegook about requiring agencies to have plans (with no actual regulations apart from paperwork). The one before that is about hazardous freight... and it contains nothing but paperwork requirements, copies of federal requirements, and "the railroad is required to have a plan". The one before that is exempting cars from stopping at railroad crossings with no trains. This all reeks of lack of internal expertise.

      The one before that is the 1991 "light rail transit" regulations, and actually appears to have been designed by someone who knows a little something about what trains are. I'm curious who wrote it, and after looking at the non-regulations which came later, I'm guessing it was nobody at CPUC. Maybe someone from San Diego Trolley or LA Metro?

  2. There's 25 kV 60 Hz voltage in the US today, at speeds ranging from glacial (the slow parts of the Morris and Essex Lines) to 240 km/h (the fast parts of the NEC in Rhode Island and Massachusetts). Are there no existing local regulations that can be lifted?

  3. Different topic: Caltrain Board Reviews Annual Budget And Ridership Numbers.
    It is great news for Caltrain that ridership keep increasing! Please see Caltrain website.


    ......Caltrain is looking at options for expanding its capacity. One possibility under consideration is the purchase of additional rail equipment. It is unlikely Caltrain would implement any schedule changes or add rail capacity before the end of this year. .....

    Above statement may not be a final decision buy is not professional. I am some how disappointed. (I was expected add more trains like last year)
    What Caltrain should address the capacity is to better utilize their assets. I would propose followings.

    Utilize Millbrae siding to provide express to local transfer and shorten the train to train spacing. (Compared with local train by passed by express at Bayshore)
    Utilize Redwood Junction siding and local train by passed by express also shorten the train to train spacing.
    Exchange Gallery car and Bombardia car by some payment to ACE, Metrolink and Sounder. (Those commuter rail have not much "Standing room only" trains)
    Utilize current fleet by reducing turn around time and middle point turn around. (North of Sunnyvale carries less than 30% of traffic density than Burlingame to Millbrae)

    1. Metrolink has a whole bunch of old Bombardier cars sitting in sidings due to the arrival of the new "Guardian Cars" or whatever they're called. I'm sure some of them could be leased to Caltrain for short term service improvements, such as lengthening the most overcrowded trains to 6 cars and being able to deploy the bilevels on the most overcrowded services. Unfortunately, it may not make sense to order more rolling stock given that it will all have to be replaced with electric trains relatively soon anyway, though maybe Caltrain would be able to work something out with a commuter rail system elsewhere that would buy the slightly used cars once Caltrain is done with them.

  4. If Caltrain leases some Bombardia Car from Metrolink, it is better to add more train. Lengthing car provides only "temporal" releaf to existing train. Another disadvantages is increasing traveling time because of reduced accerelation.
    Adding more train divert bulk of passenger from over crowded train and attract new customer at the same time.

  5. Clem,

    If and when you do a report on Altamont vs. Pacheco, which would be most welcome, I would be very interested in your comparison with this non-Altamont, non-Pacheco alignment, which would cut the LA-SJ time to well under two hours:

    It approaches the San Andreas fault south of Paicines (at grade), but separated from it by a distance twice that of the Caltrain segment in Millbrae. It requires at least 10 miles of tunnels between Gilroy and Bakersfield, and tops out at roughly 520m altitude (climbing, perhaps too quickly, from 180m along I-5). The longer tunnel comes within about 10km of the San Andreas. No doubt it would not work exactly as drawn, but the Panoche Road corridor does offer two remarkably clear and well-aligned flat sections. They even line up favorably for a Fresno connector.