24 January 2020

Electric Timetable Contest

The coveted Takt Cup
Timetable planning has long been a staple of this blog, with the support of rapid prototyping tools like Richard Mlynarik's excellent Taktulator, a calculator for "Taktverkehr," the German term for clockface timetabling. While it may take a few minutes to learn how to use the tool, you can easily punch in a stopping pattern into the Taktulator to get an instant score, based on well-researched quality metrics and train performance calculations described here almost a decade ago. The service quality score is normalized so that the 2011 timetable, not much different from today's, earns 100 points.

Working back from its long term service vision, Caltrain has started planning for the near term timetable change that will occur with the start of electric service. Through a process of elimination, Caltrain has settled on two candidate service patterns, each with six trains per peak hour per direction, linked below in the Taktulator. You can verify that the resulting string line diagrams match extremely closely with the last couple of slides in Caltrain's presentation.

Two Zone with Express
Score: 123.3
Fleet: 13 EMU + 7 diesel

Distributed Skip Stop
Score: 124.1
Fleet: 13 EMU + 7 diesel
This timetable has a bit of a "can't get there from here" problem.

Can YOU beat those scores with a better concept?

Of course, scores depend on the assumptions you make. If you assume that the downtown extension is built into San Francisco Transbay, that all the diesels are replaced by EMUs, that dwell times are shortened by system-wide level boarding, that operating practices are reformed to allow better punctuality with less padding of the timetable, that terminal turn times are shortened to match foreign practice, and that a cross-platform transfer station is built in Redwood City with a short four-track section from just north of San Carlos into Redwood City (most of these contemplated in Caltrain's long-term planning), then you can set a sky-high score. In fact, using the Taktulator, you can even quantify the service benefit of each separate improvement. If we're allowed to dream, surely this is one of the most efficient:

Richard's Finest
Score: 230.2
Fleet: 16 EMU

Unfortunately, for the start of electric service in 2023, we'll have to settle for a bit less. There is no service to San Francisco Transbay, there is a fleet of 19 EMUs available of which you probably don't want to operate more than 17 at any given time, dwell times are still long (for simplicity, assume 45 seconds everywhere), timetable padding is ample (assume 10%), terminal turns are slow (assume 15 minutes), and there are no expanded stations or passing tracks. So, with those assumptions input into the Taktulator, can you beat Caltrain's score and win the coveted Takt Cup?

Please post your suggested Taktulator timetables and scores (and your supporting rationale) below in the comments. In your comment, use a clickable hyperlink, in the format <a href="your-taktulator-link">your timetable title<\a>, for brevity and clarity.

Here's my first entry for this contest, to kick things off:

Silicon Valley All Stop
Score: 126.9
Fleet: 17 EMU + 4 diesel

This improves on Caltrain's concept by admitting what census data and Caltrain's presentation tells us: all of Silicon Valley has enormous ridership potential, and running skip-stop express service south of Menlo Park is harmful to overall service quality. In short, the Baby Bullet is bad. This timetable also makes better use of the EMU fleet, as was intended when additional trains were ordered, by running 5 EMU + 1 diesel per hour per direction, instead of 4 EMU + 2 diesel.

Can you beat my score subject to the assumptions above?

01 December 2019

Three Next Steps

Caltrain's exhaustive business plan effort has resulted in a long range service vision for how to grow the railroad to the year 2040, recently adopted by the board as official policy. This is the mountain we wish to climb. How do we climb it? One step at a time. In fact, with electrified service now unlikely to begin before 2023, there is extra time to plan and execute three next steps.

Step One: Extend Platforms

The biggest short-term constraint to growing Caltrain capacity is  limited platform length. The new EMUs will be 685 feet long when extended to eight cars, too long for many existing platforms. The existing platform lengths are shown in the graphic at right (source), with the required extensions to 700 feet highlighted in orange. The diagram shows the year of construction of each platform, proving that Caltrain is a champion of platform construction, having poured about five linear miles of new platforms over the last two decades. The amount missing is about 3500 linear feet, or a bit over two years' worth of average platform production. There are a couple of tight spots boxed in by grade crossings, most notably Burlingame (767 feet between pedestrian crossings), but most locations have plenty of space.

Longer platforms enable the operation of 7-car diesel express trains, each with about 950 seats. While diesel trains don't feature prominently in future plans, they can still fill an important interim role once they become freed up by the arrival of the EMU fleet. The diesels can easily handle longer trains. It may not look good to continue belching diesel fumes, but it gets the job done at far lower emissions per passenger-mile than by forcing unmet demand to drive instead.

At the recent going rate of 7 to 10 thousand dollars per linear foot of platform, including all capital project overheads, the entire job should cost in the range of $25 - $35 million. For perspective, that's a percent or two of the modernization budget. This project is within reach of Caltrain's existing resources and is now official policy under section (1).E.ii of the service vision. There is no plausible excuse for not undertaking it immediately, to finish by 2023 concurrently with the start of electrified revenue service.

Step Two: Add 8th Car to EMU Fleet

The EMU order currently stands at 19 seven-car trains. The seventh car was ordered in a recent exercise of an option on the original contract, at an average price of $4.7 million per car. Assuming 10% price escalation, another 19 cars to extend this fleet to 8 cars would cost about $100M. This is a large sum, but one that could be scraped together over the next year or so if some high-speed rail funding gets re-allocated to interconnected "book end" projects.

The eighth car represents a significant step up in capacity: since it has no traction equipment cabinets, bike spaces or bathrooms, it has room for a whopping 132 seats, bringing seated capacity per EMU from 667 to 799, a 20% increase. So, for an extra 5% of the modernization budget, you buy an extra 20% capacity. This should be undertaken as soon as possible.

From an emissions point of view, ordering the eighth car is far preferable to ordering additional 7-car EMU formations to displace the diesel fleet sooner. Growing the fleet before fully replacing it provides a short-term peak-hour capacity boost that will remove traffic from roads and alleviate congestion, easily offsetting the emissions of the small remaining diesel-hauled fleet. Going all-electric sooner sounds "green" if you look at Caltrain in isolation, but keeping some diesels in the short term is greener when considering the overall transportation system of which Caltrain is a part, which is what ultimately matters for the air we breathe. Seven-car diesels can be used exclusively in express service, where fewer stops and starts (which are dreadfully slow with diesel) pose less of a time penalty.

There is the small wrinkle of where to park these longer trains when they are not in service. CEMOF, the maintenance facility in San Jose, currently stores two trains end-to-end on four 1200-foot sidings where two longer trains (EMU-8 at 685 ft, or diesel+7 at 664 ft) won't fit. This means at least four trains will need to be stored somewhere else, presumably at San Francisco or San Jose, as was the practice before CEMOF was built. In a real pinch, trains can be stored during the off-peak in the controlled sidings south of Redwood Junction, with certain shoulder-of-peak trains originating and terminating at Redwood City to avoid long deadhead moves.

Step Three: Accelerate Planning for Level Boarding

Level boarding (discussed extensively on this blog) decreases trip times, improves punctuality, increases crew productivity per hour of labor, and increases the frequency of service that can be provided by a train fleet of a given size. While Caltrain's embrace of the concept has been hesitant, it is now policy under the same section (1).E.ii of the service vision adopted by the board. The next step is to get serious about planning how to actually do it, because it is a far more complicated problem than it first appears.

Caltrain staff have decided to forgo boarding using the high-level doors, and recently issued a change order to have the EMU fleet delivered with these doors replaced by plug panels. Level boarding will happen with European-style 550 mm platforms, which can't be a bad thing, although accessibility requirements are more difficult to meet in the United States. The trick is then how to get there, and how to end up with a level boarding solution that doesn't require crew assistance whenever a person of reduced mobility needs to board or alight, in the current inefficient fashion of Northeastern railroads.

The trains will require a boarding step arrangement that deploys to serve either 8-inch legacy platforms (using a drop step mechanism) or to close the gap to newly raised 550 mm platforms, during an extended transition period where some stations may have been modified before others. Due to a lack of foresight on Caltrain's part, this capability is not available on the new EMUs as procured. The EMUs will need to be retrofitted with new three-position step modules (presumably engineered by Stadler's step supplier, Bode / Schaltbau) roughly like this:

The primary engineering challenge is to meet the ADA horizontal gap requirement in Position 2, which is 3 inches maximum (in current law) and is planned to be reduced to 2 inches. The step mechanism must also deploy to the correct height without crew intervention.

The platforms will need to be raised by a bit less than 14 inches, preferably without demolishing and starting over. One intriguing way to do this cheaply and with minimal service disruption would be to re-use the existing platforms as a slab foundation, with drainage, electrical grounding and bonding, and utilities staying as they are. The platforms would first be fitted with prefabricated adjustable edge modules. An adjustable platform edge that can be jacked to the correct height at initial installation and periodically adjusted during maintenance (e.g. after track tamping) is an unavoidable requirement of meeting the demanding ADA gap specifications for unassisted level boarding.

View of a single six-foot-long 550-mm platform edge module installed on a legacy 8” platform
After suitable modifications to platform amenities, the remaining area of the platform would be raised using lightweight expanded polystyrene fill (Geofoam) and modular pavers. The pavers cover the temporary boarding step that is integral to each edge module, which is no longer needed. The resiliency of the resulting platform structure enables periodic adjustment of the platform edge jackscrews to maintain compliance with the ADA gap criteria.

The modular construction technique with edge modules and pavers lends itself to rapid “blitz” construction schedules, since no platform concrete curing is necessary. After each night's construction, the platform can be left in a usable state for the next day's service, avoiding the logistical complications of closing entire platforms during construction.

Regardless of the technical solution ultimately adopted, level boarding starts with a robust planning process to define the problem and consider all the engineering approaches. This planning process is not expensive, and it needs to be funded and staffed now that level boarding is policy.

State of Good Design

Railroad operating departments work hard to achieve and maintain what is known in industry lingo as a state of good repair (SOGR). If that's all that Caltrain is going to do in the next decade, electrification will fall flat, like a sort of MBTA with pantographs on top. We have a chance to move beyond the narrow commuter-rail SOGR mindset, striving for something far bigger: a state of good design. The three next steps described here are a small way to get started right now on the way to the visionary service improvements described in Caltrain's business plan.

25 September 2019

Risk and Opportunity in Redwood City

Lowe, a major real estate development firm, is preparing to redevelop Redwood City's Sequoia Station, an outdated strip mall adjacent to the Caltrain station, into a 12-acre mixed-use project with towers up to 17 stories tall.  If that is eye-opening to residents of Redwood City, consider that few people yet know that a greatly expanded Redwood City station is the keystone transfer node to enable the growth envisioned in Caltrain's business plan service vision. This new station will require slightly more land than the railroad already owns, and can only be located in Redwood City, the sweet spot that lies halfway between San Francisco and San Jose at the connection point to the Dumbarton rail corridor.

This creates a risk: if a commercial development project is allowed to proceed without respect to the future real estate needs of the railroad, then Caltrain will be constricted and unable to build the optimal infrastructure to support future growth.

Additional Land Needed For Caltrain

Caltrain and Samtrans have extensive land holdings at the Redwood City transit center. Still, just a bit more is needed to build a high-functioning piece of infrastructure, and be could traded for other parcels. Click to expand the map:

Land needed for future expanded station in Redwood City (shaded green)
Design Principles

The absolute worst way to build it.
Existence of this city rendering is
reason enough to be concerned.
To ensure that the Sequoia Station project becomes an exemplar transit-oriented development, rather than relegating Caltrain to the role of development-oriented transit, the rail agency and the developer should agree on some broad design principles.
  • Think Big. Redwood City is one of the few stops on the peninsula rail corridor not surrounded by a sea of low-density single-family housing. Intensive land use and transportation must fit together to achieve a dynamic yet sustainable low-carbon future.
  • Form follows function. No amount of architectural flourish or amenity can make up for a poor station design. Optimize for convenient access, easy transfers between trains and buses, short walks, direct and intuitive routes.
  • Put the station at the center of the action, right over Broadway. Don't shove it to the north, out of the way of the development. The city rendering at right shows precisely what NOT to do.
  • Configure the station as two island platforms to facilitate cross-platform transfers, without time-consuming vertical circulation or platform changes. The Caltrain business plan's staff-recommended service vision relies entirely on these Redwood City cross-platform transfers; every single train that pulls into Redwood City will make a timed transfer to another same-direction train docked at the opposite edge of the same platform. Denoting express tracks as 'F' for Fast and local tracks as 'S' for Slow, the optimal layout is FSSF with two islands, resulting in F-platform-SS-platform-F. Again, the city rendering shows precisely what NOT to do: passengers would not only have to change platforms, but also cross the tracks at grade.
  • Elevate the train station to reconnect the street grid and make the railroad permeable to pedestrians, bikes, and other traffic. A busy four-track station is fundamentally incompatible with at-grade railroad crossings, and the only reasonable way to grade separate at this location is by elevating the entire station. Obstacles to pedestrian circulation such as the Jefferson Avenue underpass would be removed. Once again, the at-grade city rendering shows what NOT to do.
  • Use four-track approaches from the north and the south. Cross-platform transfers are most efficient if trains do not have to arrive and depart sequentially using the same track, which adds about 3 minutes of delay. The best transfer is one where the two same-direction trains can arrive and depart simultaneously on their own separate tracks. Temporal separation is efficiently established by having the local train stop one station away from Redwood City (southbound at San Carlos or northbound at a new Fair Oaks station at Fifth Avenue) at each end of a new four-track segment that will ultimately measure four miles. In this arrangement, the express trains naturally gain on the local trains without a single passenger being delayed at Redwood City.
  • Include turn-back tracks. Preserve room in the right of way north and south of the station for turn back pocket sidings, between the central slow tracks. Dumbarton rail corridor trains may not necessarily "interline" or continue on the peninsula rail corridor, so it's important to give them a convenient place to transfer and turn around without fouling other train traffic on the express tracks (hence FSSF arrangement). Same thing for a possible San Mateo local, which could serve the more densely spaced stops north of Redwood City.
  • Don't be constrained by discrete city blocks. It could make sense to build structures or connect them over and across the tracks, more tightly knitting the station complex into surrounding mixed-use neighborhoods. This has some surmountable safety and liability implications, but buildings on top of busy stations are a common feature of successful cities around the world.
  • Plan for long 400-meter platforms, not Caltrain's standard 700-foot platform length (again as seen in the city rendering of what NOT to do). While statewide high-speed rail plans currently do not include a stop in Redwood City, it is becoming enough of a destination and a regional transportation node that it makes sense to build a station large enough to future-proof it for service by long high-speed trains, regardless of what the California High-Speed Rail Authority might have to say about it.
  • Think ahead about construction sequencing. Redwood City should be grade separated in one project from Whipple to Route 84, including the elevated station, taking advantage of Caltrain's land holdings to minimize the use of temporary tracks. A shoo-fly track would have to be built on Pennsylvania Avenue (within the railroad right of way) to make room for construction of the western two-track viaduct. Trains would begin using the elevated station while a second eastern two-track viaduct is constructed. Pennsylvania Avenue could re-open later, under the new four-track viaduct. Construction sequencing may drive how much extra land is needed for the railroad, so it's important to think it through up front.
If these design principles are respected, the re-development of Sequoia Station will present not a risk but an amazing opportunity to enhance Redwood City by realizing its full potential as the fulcrum of the Caltrain corridor and of a new regional express network reaching across the Dumbarton bridge and beyond.

01 September 2019

Electrification Delayed

Caltrain's electrification project is showing ominous signs of falling badly behind schedule. There are at least five bearish indicators:

Slippery milestone
Slipping Milestones. One key milestone reported in the project's monthly progress reports is known as "Electrification Substantial Completion." From the December 2018 report to the July 2019 report (over a span of 7 months), the milestone has slipped from 6/23/2021 to 12/31/2021 (a bit over 6 months). When a major milestone slips almost day for day, you know the project has gone sideways. The latest PMOC report from the FTA shows that the contractor's date for this key milestone has slipped well into 2022, over a thousand days late relative to the milestone date promised when the contract was signed.

Severely under spend plan
Significant Under-Spending. The amount of money spent to date is about $640 million less than planned at the start of the project. If the value of the work accomplished is commensurate with the amount spent, then the project is 1.5 years behind schedule. However, there are strong indications of inefficiencies (such as "differing site conditions" disrupting foundation installation) and unplanned scope (such as the new grade crossing constant warning time solution) that make it exceedingly likely that the value earned so far is less than had been planned for the amount spent. From an earned value perspective, the CPI is likely under 1 (over budget) and the SPI below 0.6 (further behind schedule than the spend curve might imply).

The little engine that couldn't
Foundation Chaos. As is plainly obvious to anyone riding the train, foundation installation is not a spatially or temporally orderly process. Digging into the ground reveals old utilities, and often reveals the recently-installed CBOSS fiber optic cables, evidently placed by the contractor where it was easiest (right where foundations need to go) with the as-built configuration either incorrectly documented or not at all. This is another CBOSS issue that could end up in court. Conflict with these cables does not bode well for PTC testing or activation, or for the cost of foundation and pole redesign and relocation. Recent indicators show a slight uptick of foundation productivity, but it still lags well below the monthly average of 174 that must now be sustained every month to complete on time. The all-time record is 122, and indications are that August 2019 totals have slid back considerably below trend.

Missing tasks are delayed and
on the critical path
Missing Schedule Tasks. By all accounts, the long pole in the tent (the critical path of the Balfour Beatty schedule) is the design, installation and testing of the signal system modifications, including the new grade crossing warning system. However, such a task is nowhere to be found in the schedule published in Appendix C of the monthly report, which obscures any insight into the true status of the project. Having recently set $150 million on fire with CBOSS, Caltrain is understandably skittish about revealing further unforeseen costs and delays associated with signalling, but it seems inexcusable at this juncture that the public master schedule would show only "OCS," "Traction Power," and "Segment Testing" tasks for the electrification contract, when all the action is in the missing task "Signal System Modifications," which is very much on the critical path in Caltrain's internal schedule and the contractor's schedule.

Proliferation of Schedules. There is apparently no agreement between Caltrain and their contractor on what the real program schedule is. The public schedule in the monthly report is served with a cautionary statement that Balfour Beatty is reporting a significant delay, but the completion milestone is still optimistically set to 12/31/2021. When you end up with several schedules, there is effectively no longer a project schedule. It's anyone's guess when the project will be done, and chances are increasing rapidly that it won't be in 2022, despite Caltrain's increasingly desperate insistence that everything is fine.

Right now would be a good time to come clean about what's really going on. Total transparency is the only saving grace that can spare Caltrain from accusations of project management incompetence.

28 July 2019

Emergency Exit Fail

Caltrain's new EMU train cars have an unusual configuration with two sets of doors. The lower level doors will be used at existing Caltrain stations, while the intermediate level doors (above the wheels at the ends of each car) are intended to be used at an undetermined date in the 2030s once these trains begin sharing stations with California high-speed rail, which will use high-floor trains and high platforms with boarding at about 50" above the rail. The California High-Speed Rail Authority, which Caltrain cryptically refers to as "external stakeholders," required this design feature as a condition of funding Caltrain's modernization to the tune of $750M, to maintain the option of sharing platforms at future HSR stations in San Francisco, Millbrae and San Jose.

The Original Plan

To maximize the short-term seating capacity of the new trains until the 2030s, Caltrain specified that the intermediate level should have temporary flip-up seats installed in front of the unused doors, five per door vestibule, with the seating blocking off the doors like this:
Configuration of intermediate level in A, B, C, E, and G cars
Because EMU cars are filled with electrical cabinets (labeled with yellow lightning bolts), the seating capacity of the train is reduced compared to a conventional train. This is the price you pay for not having a locomotive; all the bits that make the train go still need to find a place, which makes for a challenging packaging problem in a bi-level train. The reduced seating capacity of the train has been controversial and makes these temporary seats quite important. For each 7-car train, there are 70 of these intermediate level flip-up seats that make up a non-trivial 10% of the overall seating capacity of 667.

At some undetermined future date when the intermediate doors would be needed for compatibility with high platforms, the blue flip-up seating modules would be removed from the intermediate level.

A Regulatory Conundrum

In the design of any new train, federal safety regulations require that any passenger seating compartment be fitted with at least two emergency exit windows (for passenger egress) and two rescue access windows (for first responder ingress). The intermediate level counts as a passenger compartment because these flip-up seats are located within it. However, the intermediate level does not have what regulations consider to be a window; the only opening to the outside is through the doors. This set up a conflict with safety regulations.

In late 2017, Caltrain petitioned the Federal Railroad Administration for a waiver (docket FRA-2018-0003) by arguing that the emergency release feature of the doors would provide an equivalent level of safety, despite not meeting the letter of the regulation, allowing emergency access by climbing over the seat backs.

In June 2018, the FRA denied Caltrain's request because the flip-up seating installed longitudinally such that it blocks the doors could impede egress and access and therefore did not meet the intent of the regulation. The FRA stated that "the absence of need for these intermediate level doors to support current revenue boarding and alighting requirements does not negate the necessity for an unobstructed path in the event of an emergency." Curiously, this unobstructed path requirement applies only to doors, not to windows!

Implicitly, Solution A is to remove all seating from the intermediate level of the affected cars, which effectively sidesteps the emergency window requirement. But given that seating in Caltrain's EMUs is already quite limited, this solution seems like a non-starter as it would reduce seating capacity of a 7-car train by 9% from 667 seats to just 617 seats.
Solution A: not a passenger seating compartment
The FRA helpfully suggested some other possibilities.

Solution B: equip the intermediate level doors with a regulation-size emergency window of minimum dimensions 26" wide by 24" high. Unfortunately, that is too large for the dual-leaf design of the train doors; in other words, the window in each door leaf is too narrow to function as an emergency window.
Solution B: the minimum clear opening is too big for dual-leaf doors
Solution C: replace the intermediate level doors with a plug panel (essentially, a structural wall panel that does not function as a door) fitted with a regulation-size emergency window of minimum dimensions 26" wide by 24" high, until such time as the door-blocking seating is removed, the panel is removed, and the doors and platform bridge plates are re-installed.

Solution C: doors replaced by plug panels
Caltrain is now in the process of pursuing Solution C, plug panels. This change order is expected to cost about $4 million total up front, about $30000 per car, or $7000 per door. When intermediate-level doors are required a decade or more from now, a net sum of approximately another $10 million ($14 million future installation cost to be set aside, minus $4 million of door maintenance savings) would be needed to retrofit them. That is a LOT of money for a change that fundamentally reduces and complicates compatibility with HSR stations and platforms.

Other Solutions

There are other solutions that strike a better balance of functionality and simplicity without a seven-figure cost impact.

Solution D: short of removing all the seating from the intermediate level vestibule, the regulations require only one emergency window (instead of two) if there are four or fewer seats in the compartment. Removing seats from one side only and applying for a new waiver to allow unobstructed use of one of the doors in lieu of a single emergency window could work, addressing the FRA's stated concern with door obstruction. This would reduce seating capacity of a 7-car train by just 22 seats or 3% (5 seats lost in cars A and B, and 4 seats lost in cars C, E and G).
Solution D: reduced seating with unobstructed emergency access
Solution E: reconfigure the mounting bracket for the flip-up seating so that seats flip up and out of the way of the doors when not used, allowing the unimpeded use of both doors in lieu of emergency windows. This solution requires applying for a new waiver to allow the use of doors in lieu of emergency windows, but also addresses the FRA's stated concern with door obstruction. Placing the flip up seats in this manner would reduce the clear width of the door opening by a couple of inches on each side, from 51" to about 47", with no reduction to seating capacity.
Solution E: change flip-up seating orientation to provide unobstructed door access
(flip-up seats are shown in use; they fold flush against wall when not occupied)
Solution E would require no modifications whatsoever when the intermediate level doors are needed in the future, and could be implemented at all doors throughout the train including the lower level, adding seating capacity. Seats placed in doorways may sound like a bad idea, but in a crowded train, social signaling fairly quickly communicates to occupants of these seats that it's time to stand up and make way. This is the French "strapontin" seating in common use on some of the busiest rail lines in Paris:

Flip-up seats in a doorway of a brand new Bombardier EMU on Paris RER line D.
(foreground at left) credit: Wikipedia / KiHa 52
Indeed, the photo above, taken inside the same Bombardier EMU often vaunted in front of the Caltrain board by a certain member of the public as having so much more seating than Stadler's EMU, shows one of the secrets of achieving very high seating densities: flip-up seating in all doorways. The other three secrets are five-abreast seating, not having as much space dedicated to bikes, and lower acceleration performance that requires fewer electrical cabinets, leaving more space for seats. After adjusting for these four factors, it turns out that the Bombardier EMU provides no higher seating density than the Stadler EMU.

Ultimately, it is entirely possible that Caltrain simply does not wish to interface with high-speed rail in any station as a matter of policy, because it would require sharing and collaborating with another agency, and solving a somewhat complicated ADA compliance problem. Which agency would voluntarily bring that upon itself? Caltrain already took the HSR money, and installing plugs will "erase" the clunky and unpalatable concession they made in the name of compatibility, with the further bonus of not requiring another run at the FRA for a new waiver. The complicated ADA compliance issues associated with interior lifts are kicked as far down the road as possible!

No matter how you look at it, Caltrain's chosen approach is a ~$15 million mistake that reduces and complicates compatibility with HSR stations and platforms. There are cheaper, simpler and easier ways to achieve compliance with emergency window regulations. It's not too late to change course.