25 May 2014

High Voltage Rulemaking Update

Caltrain mascot?
(photo by wwarby)

Feathers are really starting to fly in the Public Utilities Commission proceeding to establish a regulatory framework for 25 kV railroad electrification in California, under CPUC docket number R1303009.  Electric utilities and freight railroads are putting up a big fight against the California High-Speed Rail Authority that threatens to leave Caltrain hanging out to dry.

With the impending electrification of the peninsula corridor clearly in mind, the freight railroads asserted in January comments that "it remains unclear if the proposed rules will be sufficient for high-speed train operation in shared rights-of-way” and that “[i]f the CHSRA does not amend its petition to clearly state the intended scope of the rulemaking, the Commission should order further workshops to ensure that the proposed rules are carefully vetted out for application in shared rights-of-way."

Freight railroads are concerned about a number of compatibility issues, including electromagnetic interference with their signaling systems and vertical clearance for their freight cars.  Electrification could impair vertical clearances especially under bridges.

The CHSRA's response, filed in late March, was crystal clear:
The purpose of these rules is to establish uniform safety requirements governing the design, construction, operation and maintenance of 25 kV ac (alternating current) Railroad Electrification Overhead Contact Systems (OCS) constructed in the State of California in right-of-ways dedicated solely to passenger use with no public highway-rail grade crossings and in which freight operations do not occur.

(...)

[The freight railroads] know that the proposed General Order is not ambiguous and that it will not apply to track where freight operations occur. Their continuing refusal to be satisfied on this point reveals a desire to delay and obstruct this proceeding.
The peninsula corridor, of course, meets none of these criteria.  It is not dedicated solely to passenger use.  It has numerous highway-rail grade crossings.  Freight operations occur daily.  The freight railroads are understandably worried about this issue of scope, given that the legislature has allocated more than a half-billion dollars of HSR funding to electrifying the peninsula corridor; Caltrain plans to complete the electrification project in just five years.

Where does that leave Caltrain?
  1. No regulatory framework exists for Caltrain's electrification project
  2. CHSRA is explicitly not planning to establish such a framework
  3. The freight railroads are vigorously opposed to the idea
  4. Time is running out
That leaves Caltrain with few options.

The Short Line Option

It has been suggested that the rulemaking process would be less contentious if a smaller "short-line" freight operator were to buy the trackage rights UPRR enjoys on the peninsula corridor.  Presumably, such a short-line operator would be less adversarial in the negotiation of a mutually agreeable regulatory framework and technical solution for electrification.

This scenario unfortunately fails to take into consideration the precedent-setting nature of placing 25 kV electrification over any track where freight operations occur, regardless of ownership.  The big freight railroads, UPRR and BNSF, will be no less interested in such a proceeding at the CPUC than if their own tracks were being electrified.

The Nuclear Option

Section 8.3.c of the trackage rights agreement with UPRR specifically allows for the wholesale abandonment of freight service on the peninsula, should Caltrain "demonstrate a reasonably certain need to commence construction on all or substantially all of the length of the Joint Facilities of a transportation system that is a significant change in the method of delivery of Commuter Service which would be incompatible with Freight Service."  While 25 kV electrification over freight trains doesn't seem to be such a big deal on the East Coast or the rest of the world, the freight railroads' arguments in the latest CPUC proceedings could be construed as a belief that 25 kV electrification is fundamentally incompatible with freight operations in California.  Do we really want to go there?

Whatever option is pursued, there is little doubt that the freight railroads will have a big hand in the outcome, and that lawyers and judges will be involved.  The freight railroads have clearly demonstrated that they have:
  • Intimate familiarity with the intricacies of the CPUC rulemaking process
  • Ready access to a deep bench of experts who can testify on any technical subject
  • An army of well-paid lawyers
Caltrain will bring a knife to a gunfight if they don't get their act together soon.

44 comments:

  1. Clem,

    If Caltrain management had anyone competent,they would leap at the chance to exercise the abandonment clause in Sec 8.3.c The freight rail companies are already making the case that CHSRA-style electrification is incompatible with freight. CHSRA, on the other hand, says their electrification standard is not intended to apply to trackage with freight. Bingo. Caltrain declares that, due to funding "CalMod" with HSR money, Caltrain has to deploy CHSRA-compatible catenary.

    At least 9 months before commencing construction of overhead catenary, Caltrain files with the STB for abandonment. The trackage-rights agreement with SP (now owned by UPRR) says the "User" (UPRR) will not oppose abandonment proceedings; Bingo. In that one fell swoop, Caltrain elminates freight from their corridor. It's not a "nuclear option", its the intransigent UPRR and BNSF being hoist by their own petards: their objections filed with CPUC.

    No more freight on the Caltrain corridor. No more freight-compatible (shallow, more expensive) grades. No need to engineer bridges or overpasses for FRA dinosaur freight trains. Win/win, with one *very* notable exception: diverting all current rail freight on the Peninsula, onto trucks.

    Interestingly, you leave out the most desirable outcome: that CPUC drags the freight railroads,kicking and screaming, into the early 20th century, and allow catenary over freight lines. Is there in California that makes California electrons different from electrons on the NEC, or the rest of the world?

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  2. Freight and commuter trains interoperate just fine in the Northeast; I see no reason they couldn’t here. CPUC could use whatever existing regulations they have as a starting point, then explicitly declare that it will have no precedent for future regulations.

    Perhaps I’m missing some obvious problem with this plan. It just pains me to abandon freight entirely, though.

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  3. CPUC *don't* *have* any relevant regulations. They have regulatoins for 750v DC, single-wire, electrification for streetcars using trolley poles. Those regulations are irrelevant for 25kV electrification over existing freight lines. Different heights, vaslty different voltages, different clearances.

    Remember, this is the CPUC which thinks it's important to regulate gantries for manhandling huge blocks of ice into wooden, non-mechanical "refrigerator" (ice-cooled) cars.

    Or do you mean using NEC regulations to cover Caltrain electrification? Nah, electric fields in California are "unique and special".... (heavy sarcasm)

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  4. Reality Check26 May, 2014 10:31

    UNION PACIFIC RAILROAD COMPANY’S REPLY TO THE CALIFORNIA HIGH- SPEED RAIL AUTHORITY’S RESPONSE IN OPPOSITION TO MOTIONS FOR EVIDENTIARY HEARINGS

    [...]

    II. DISCUSSION

    A project like CHSRA’s has never been built in the United States. Yet, CHSRA wishes to start construction before new federally mandated Positive Train Control (“PTC”) systems have been implemented, and before any testing has been done to determine whether there could be a conflict between the operation of PTC and nearby CHSRA electrical systems. The proposed project also presents serious questions about potential conflicts with existing railroad signal systems, necessary clearances to prevent these interferences, and the introduction of new hazards to employee and public safety. If these issues are not resolved correctly, CHSRA risks spending billions of dollars to build a railroad that will not function. This is not hyperbole: Getting it wrong will mean CHSRA trains cannot move until millions or billions more are spent to fix fundamental problems.

    This makes it difficult to understand why CHSRA would oppose Union Pacific’s request for a hearing.

    [...]

    B. CHSRA Has Not Provided Extensive Research Related To The Electromagnetic Interference (“EMI”) Issues Identified In Union Pacific’s Motion.

    In its response, CHSRA contends that it “has already provided extensive information” during the technical panel workshops to address Union Pacific’s concerns regarding the impact of EMI. CHSRA misrepresents not only the information it provided, but the discussions that took place during the technical workshops. David McCord, Union Pacific’s electrical expert on signal interference, was present at all of the technical panel workshops. At several of the workshops, he discussed the reports upon which CHSRA relies for its position that there will be little to no impact on freight systems due to EMI. At those workshops, Mr. McCord relayed to CHSRA that the reports are inadequate because the railroad systems at issue in those reports do not operate at speeds above 150 m.p.h.; CHSRA proposes operating trains at 220 m.p.h.

    CHSRA conceded in its Reply Comments that its project is unique because trains will reach speeds above 150 m.p.h. It is not the 25 kv system alone that could create EMI; rather, the speeds at which the trains will travel influences the potential for EMI. Two systems having the same voltage and similar design does not mean they will have the same EMI. Induced voltage is proportional to current. Power is equal to current times voltage. To overcome wind resistance and friction, the faster trains move, the more power they will require. Since the voltage will remain constant, more power will needed to move CHSRA trains at 220 m.p.h. Accordingly, the current must also increase. As current increases, the EMI will proportionally increase as well. There remain, therefore, factual issues to resolve as to whether or not the proposed rules will adequately address EMI to prevent interference with existing freight signal and PTC systems. An additional issue is the design, construction, and implementation of PTC systems, which are currently not in operation and have not been tested or modeled in electrified corridors.

    [...]

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    1. I knew there was a use for PTC!

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    2. "[[CHSRA's]] project is unique because trains will reach speeds above 150 m.p.h"

      ROTFL! how can anyone take these ignoramuses seriously??

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    3. This would be funny if it wasn't real. But it's real, so it's not at all funny.

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  5. kiwi.jonathan: Yes, I meant using NEC regulations for the Peninsula, and perhaps Metrolink if similar issues arise in their territory. I certainly wouldn’t expect CPUC to come up with this on their own, but *maybe* they’ll agree if Caltrain pushes hard enough and the freight railroads are willing to go along too.

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  6. Variable-tension PRR style catenary on Caltrain? Oh, joy.

    Besides, your suggestion would require technical competence within Caltrain management and decision-makers.

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    1. Don't confuse regulations with design. There is no PRR catenary in Massachusetts or Rhode Island.

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    2. Or Connecticut. CTDOT is busy replacing the NYNHHRR style stuff.

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    3. Which makes me ask: *is* there a single regulatory catenary standard for the NEC? Or is it state-by-state? Do the voltage/frequency changes occur at state boundaries, or simply wherever legacy rail lines meet?

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    4. Adirondacker1280027 May, 2014 19:37

      No, no, no and no.

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    5. If the regulations on overhead catenary aren't state-by-state, what "regulations" is Anonymous suggesting we adopt?

      Web-searching suggests Metro North had catenary was low as 15ft 4in in 2007. I've read that the nominal height of NEC catenary over open line 20 ft 6in, and elsewhere that it's 23 ft. Apparenlty NS runs triple-height auto-trains with a clearance of 19ft under 20ft 6in wire. I've also seen claims the NEC catenary snakes up and down irregularly; which means actual minimum cleariance goes as low as 5in under 11kV, and 7in on 25kV.


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    6. Clem,

      if CalTrain could eliminate freight from the Peninsula by electrifying, do you think that would make any difference to the PAMPA communities' attitudes?

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    7. Probably none. Say what you will about PAMPA, their leaders (city councils, committees, staffs) are far more astute about rail corridor matters than they were five years ago. I would hazard a guess that they would probably be concerned about extra truck traffic on 101, including haz mat.

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    8. Why would they want to eliminate freight from the peninsula? Obviously full-on Plate K double-stack/auto-rack clearances are overkill; but seems shortsighted to just eliminate all freight traffic.

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    9. It does seem short-sighted, but if the FRA, CPUC, UP, Port of SF, etc etc are going to make us try and jump through (costly) hoops to accommodate freight, often at the expense of passenger service, then eliminating freight may be the preferable option.

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    10. Eliminating platform height restrictions and reducing TOR clearance height for passenger trains while simultaneously loosening temporal movement and maximum TOR restrictions for freight train operations can all be accomplished by rerouting all SF Peninsula freight trains to a Dumbarton Bridge−US101 center alignment. It is only 16 miles between the dormant Dumbarton freight line Bridge crossing US101 and a point opposite LAX; 800 feet across a vacant section to the present Caltrain right-of-way. A UP executive said such a re-alignment would significantly shorten a daily freight run between San Francisco and its East Bay terminal.
      The 101 freeway median is nearly perfectly flat except when crossing the Woodside Road underpass. A single track line with Grandfather Rights to exist without grade separations plus modest freight train only signaling requirements could be economically established in order to sharply reduce anticipated SF Peninsula passenger service improvement costs presently being contemplated.

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    11. John, that's delusional. There *is* no median for part of that stretch of 101. Driving on the inside lane, you're driving adjacent to a concrete barrier, in one direction or the other, a lot of the way. . Sure, For part of the distance, there's a thin shoulder on one side of that concrete barrier; sometimes both. But enough for a freight right-of-way? I don't think so, and Google Maps satellite photos confirm it.

      Never mind the obvious typo, LAX should be SFO.

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    12. Reality Check28 May, 2014 17:25

      Agreed, totally not going to happen ... ever -- even if there were a median strip wide enough to accommodate a single track.

      Also, due to Granite Rock (and others), the Port of Redwood City is one of the -- if not the -- single biggest freight car destinations/origins on the Peninsula. Of course, you can loop freights into there from Dumbarton via Redwood Junction and along Chestnut Street without ever touching the Caltrain mainline tracks.

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    13. Yep, iI worked at the end of Seaport Blvd for over a year. Granite Rock gets huge (for the Peninsula) rakes of hopper cars full of rocks.

      Everyone seems to be ignoring the fact that the Dumbarton rail bridge is inoperable. after the arson in 1998 (and mothballd for about a decade before that). And that MTC is trying to "forgive" the "loan" they took from Dumbarton Rail funds appproved by voters Some people call that 'stealing"......

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    14. Reality Check28 May, 2014 18:45

      Careful. Ignoring is not the same as not knowing.

      My brother and I carefully walked out to the open swing span from the EPA side not long before the fire. Wish I had taken some photos.

      The arson only made an already bad/inoperable/impassable bridge worse. The part that burned was in pretty bad shape; it would have required a rebuild anyway.

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    15. Fair point. But I usually choose my words rather precisely, and (until now!) I'll stick by "ignoring". (("ignoring the broken bridge in the room"?)) Yes, the bridge deteriorated before the arson. i don't know first-hand, but I have read that before the arson, it was considered repairable After, it's definitely rebuild territory. Not that I'm suggesting the Dumbarton Rail proposal would've continued with a swing bridge, appealing as it would be to certain Foamers.

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  7. Granite Rock moves rock trains that originate from Aromas north to its yards in San Jose, Redwood City and South San Francisco. They pay by the ton-mile. Taking a detour through Alviso to the Dumbarton bridge would add substantially to their distance and thus their cost for delivery to Redwood City and South San Francisco.

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    1. The Dumbarton rail bridge is no longer usable by trains, as part of it burnt down. If BART stops stealing Dumbarton rail money then maybe it'll get repaired at some point.

      And I think we all agree that abandoning freight on the peninsula isn't the most desirable outcome, but it may be the only option if UP and the CPUC refuse to cooperate.

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  8. One alternative to total freight abandonment on the Peninsula, would be a partial abandonment. Reduce the loading-gauge to the greater of AAR Plate F and MIL-STD-1366 (STRACNET). Bruce McF suggested that, in response to Clem's "Electrification Blues" blog post of Nov 2009.

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  9. @kiwi.jonathan @ Clem - I think removing freight from the Peninsula would be welcomed by residents but they'd have to understand that other issues would need work (like what alternate methods are there to move freight).

    I agree with Clem that there would need to be a focus on moving that freight off the road - since traffic is something everyone is concerned with ( cue conversation about renovated Dumbarton rail or other ideas).

    One of the things that always upsets PAMPA residents about HSR is that an elevated structure would mean also elevating the freight - which means the noise would increase significantly (not from HSR - which would be quieter than diesel (ignoring the grade crossings/quiet zone issue for the moment) but from the fact that all the rocks being moved are already REALLY loud).

    Also, not having freight means that if cities were looking at a covered trench (which PA is currently studying), the grade is easier to work with - thus reducing cost. Whether that cost is paid for by the cities or HSR or some combination thereof - a cheaper trench is good for everyone.

    The frustrating thing is this was all discussed at great length in various meetings - including the PA Teach-in, community meetings and Policy working group meetings that HSR/Caltrain formed with all the cities between SF and SJ per CARRD's request for Context Sensitive Solutions (CSS) - and then everything was ignored.

    Hence the general distrust for HSR at this point - but also hence the enlightenment about the ROW overall by the community.



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    1. Covered trenches, known as tunnels in the rest of the world, are very expensive to build. I suppose they could create a special tax district to pay for it. Do you prefer increased property taxes, special income taxes, sales taxes or a combination to pay for it all?
      If they are gonna be digging tunnels there are those pesky creeks to consider. Diverting creeks cost a lot of money. It gets the tree huggers very very upset. The creeks, silly silly creeks have a nasty tendency to fill up the old creek bed during especially wet storms. Unless you spend even more money to assure it won't. There's alway the option of tunneling through the bucolic suburbs that are there because there's a train and just leaving the freights and the local passenger service to the quaint and scenic ROW that has all those charming grade crossings. And until that's done use the quaint and charming existing ROW for everything.

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    2. I'll just reiterate what has been our point all along - Any and all alternatives are open for discussion when discussions are being had and information is being shared appropriately and honestly. Elimination of freight, cost of trenches, impact on creeks, etc. are all salient points - but without everyone talking to each other with real information about costs and impacts, there is no way to educate everyone about the implications of each decision and then work out a solution.

      CARRD's CSS suggestion was always to find a way to balance community goals and transportation goals. The idea being if both the community and the agency feel they share a common goal and can work together - then both will be happy to pony up money. (Remember the idea that 1/3 of the money was going to come from local communities - hard to do that when they've pissed everyone off).

      I think the freight conversation is relevant and worth having and I wouldn't write it off.

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    3. Why should people who were bright enough to not move next to the railroad tracks have to pay for people who bought the cheap real estate near the tracks can get their property values increased? Up on a structure is good enough other places why isn't good enough in Palo Alto or Menlo Park?

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    4. It sounds like you already know the answer!

      I agree that CSS or some other form of a collaborative method could work, but only if there is good faith on all sides. The HSR people failed on that count, but so did the Daily Post by whipping everybody up with incessant fearmongering about eminent domain. I think at this point the well has been thoroughly poisoned.

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    5. Except that CAHSRA is a government agency that ostensibly works for the people. They can't just take their ball and go home because the Daily Post was obstreperous.

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    6. All this to give San Francisco's Hoity-Toity a "one-seat-ride" south! Far better, safer, more reliable, and cheaper: end HSR to the Bay Area at San Jose, with good transfers there to Caltrain, Capitol Corridor, SV BART, and VTA Light Rail. Defer HSR along Caltrain until it is fully grade separated.
      -----
      From San Jose up-grade the UP/Amtrak East Bay Mulford line on to Sacramento, with a transfer station at the BART overhead in Oakland, 6 minute from San Francisco's Embarcadero station with a train every 4 minutes.
      -----
      Don't squander more HSR money on Caltrain.

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    7. I tried to publish my name: Robert S. Allen

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    8. It's okay, we know who you are even without the byline.

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    9. I have to wonder, Robert S. Allen, why you appear to value the lives of HSR passengers above the lives of Caltrain passengers. Both train types will travel through grade crossings at the same speed, and they will have substantially the same crashworthiness. Following your argument to its logical conclusion, we should suspend Caltrain service until the corridor is fully grade-separated. Failing this women and children might die!

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    10. Robert S. Allen, alias Anonymous, certainly has a valid concern for Caltrain safety due an incomplete grade-separation effort. During the period from when Joint Powers Board first took control of Southern Pacific’s San Francisco Peninsula Commuter service until about a year ago 200 people have been struck and killed along that property. During the same period only 60 people died along the completely-grade-separated BART system.
      Obviously extending Caltrain’s Grade Separation Program would definitely reduce the casualty rate. But economically accommodating a 25 KVA over-head-catenary electrification will force the creation of high-level-rail-over-intersecting-roadway grade separation designs. High-level-track-ways allow train-noise to be widely broadcast over surrounding neighborhoods even after sound-walls are place. Therefore maximum tolerable train speeds will be sharply reduced. The concrete piers needed to support the rail-over-crossing bridges are usually perpendicular too and centered on the present rail structure. In order to maintain present rail service a low speed temporary track is usually built after intervening trees and adjacent structures are destroyed. Then rail-bridge-construction and concrete curing can proceed. In order to minimize adjacent tree destruction a compromise solution will likely result in few additional passing tracks and FSSF track-ways with center-of-the-right-of-way station platforms will be banished. (A FSSF scheme would minimize the number of switches encountered by high-speed-trains allowing simultaneously improved safety and greater speeds. Also a largely continuous vacant center would allow infill stations, platform lengthening, and gap-train storage in the best position for trains to be added to the on-going-service in order to maintain timely-performance in spite of police activity, rolling stock failure, or unusually heavy demand. )
      Alternatively open-cut Caltrain grade separations could be built. During the initial construction phase over-crossing bridge piers and retaining walls could be placed between the present railway’s loading gauge and the railway property line without requiring a parallel track-way, thus avoiding serious damage to adjacent property or persistent train service disruption. The initial below-grade well clear of present train operations position of these ‘cast in place’ structures would foster sufficient patience so that an undisturbed moist environment for an extended period would likely be provided for effectively curing this type of often massive concrete infrastructure. (Note: A Portland Cement cure cycle chart indicates a 6 month continuously moist environment cure will provide a 56% stronger concrete structure than a one month period with an initial 3 day moist period cure cycle.) With bridge piers and earth retaining walls solidly in place during a summer weekend when rain is unlikely, schools are closed, and many spare transit buses are available for maintaining a connection with both halves of an on-going rail service, the at-grade tracks plus earth between the new retaining walls could be removed and new tracks placed within the new open-cut right-of-way. Rapidly deployable combat engineer bridges supported by the permanent over-crossing piers could convey traffic across the open-cut railroad until lower cost esthetically tolerable permanent over-crossing bridges are constructed.

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    11. I think it is important to note, for context, that the peninsula corridor is already 62% grade-separated today. Only 38% of the road crossings still require grade separations.

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    12. Mr. Allen is a former BART Director, 1974-1988, retired Southern Pacific executive. He was actually one of the more reasonable BART Directors and actually rode BART. Any time I attended a BART Board meeting back in those days, I would see Mr. Allen on BART. He has got to be 75-80 years old now.

      As for “squandering” HSR money on Caltrain, he knows that if Caltrain were electrified and grade separated and run the way it should be, that would end all hope of the BART manifest destiny of “ringing-the-bay” with BART. It would also expose the shortcomings of BART (astronomical cost, lack of express service, limited capacity per train car, lack of a monthly pass, etc.) People would realize that there is something better than BART at a fraction of the cost.

      During his tenure as A BART Director there was ultra strong sentiment against Caltrain, not so much from Allen though. The anti-Caltrain mind-set was such that Caltrain will never carry any ridership over 20,000, Caltrain improvements will suck away all transit monies for decades to come. There were heated debates over extending Caltrain to downtown SF vs. extending BART to SFO vs. east bay BART extensions. MTC was in the middle of all this garbage too. Some of this anti-Caltrain attitude still exists today.

      Remember, Southern Pacific tried for years to abandon the peninsula train service, so maybe it’s inherent in Mr. Allen’s blood. Maybe he is becoming senile in his old age.

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    13. Maybe that last sentence was uncalled for.

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  10. John Bacon: A lot of those deaths come as a result of people stepping in front of Baby Bullets on station platforms. Grade separation won't help with that.

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    1. Reality Check10 June, 2014 16:15

      Thinking back over the years, most deaths by far are suicides ... and are away from grade crossings ... while the very small fraction of deaths that are ruled accidental are almost all at crossings.

      So grade seps would only cut accidental deaths, of which there are already very few, nearly to zero ... while suicides would hardly -- if at all -- be affected.

      Makes sense, right?

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    2. Makes sense. Fare gates and all the protections to keep people away from the third rail are deterrents to suicide-by-BART.

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