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.