Level Boarding is Legal in California

Arrow level boarding platforms
at San Bernardino, CA

Comments to old posts on this blog are stored in a moderation queue that your author doesn't visit often enough. Over a year ago, commenter jpk122s discovered quite a gem: an official resolution by the CPUC (California Public Utility Commission) that level boarding station platforms are not bound by General Order No. 26-D section 3.4. This means it's nerd time.

Some California Background

The CPUC regulates all railroads in California, including their clearance dimensions under General Order 26-D. This regulation, originally published in 1948, requires all mainline train platforms to be no higher than 8 inches above top of rail per section 3.3. If you want to build a station platform higher than 8 inches, it needs to be set back at least 7'6" from the track center line per section 3.4. This requirement is deeply inscribed into the built environment of train stations around California, including Caltrain's.

• The taller platforms used for boarding passengers with reduced mobility, known as "mini-highs" and cluttering the north end of most Caltrain station platforms with ramps and railings (see diagram below), must be set back at least 7'6" per section 3.4. This is quite far from the track, requiring the use of bridge plates to cross the wide (~3 foot) gap between the mini-high and the train.
  
• The 48" level boarding platforms used by SMART (in Sonoma and Marin counties) are closer than section 3.4 requires, but as mitigation, a set of gauntlet tracks allows freight trains to stay clear.
• The 23.5" (ish) level boarding platforms used by Sprinter (Oceanside to Escondido) are closer than section 3.4 requires, but as mitigation, they have folding edges that tilt up and out of the way of freight trains that pass during the night.

Current Caltrain platform standards

These examples are all Rube Goldberg solutions that are expensive, clunky and inconvenient – especially when considering that nothing physically precludes freight trains operating past high platforms, as is common practice on the east coast.

Then, along came the San Bernardino County Transportation Authority, with a request for an exemption from section 3.4.

Level Boading for Arrow

Arrow is the brand name for a new passenger rail service linking San Bernardino to Redlands. This service uses Stadler FLIRT diesel multiple units, of a standard vehicle design sold in more than 2500 copies around the world. The platforms are built for level boarding at 23.5" to comply with the accessibility requirements of the Americans with Disabilities Act (ADA). Rather than contrive a new technical solution to comply with GO 26-D section 3.4, the parent agency did something unusual: they asked for an exemption.

The May 5th, 2022 resolution adopted by the CPUC, an agency known for its conservatism and dogged focus on safety, was surprising: "The RSD [Rail Safety Division] has determined that an exemption from General Order 26-D, Section 3.4 is not necessary since it is preempted by the federal Americans with Disabilities Act (ADA)." Section 3.4 (a state regulation enacted in 1948) is preempted by the ADA (a federal law enacted in 1990). The resolution continues:

General Order 26-D, Section 3.4, sets forth a minimum clearance requirement for station platforms. However, this provision of General Order 26-D is preempted by the ADA, which requires a different platform height and distance from track center line to accommodate the introduction of the Multi Unit (MU) equipment– and thus, results in a smaller clearance area – than what is set forth in General Order 26-D, Section 3.4.

Interestingly, the freight railroads that usually complain about the slightest infringements to their operating environment did not comment on the resolution before it was adopted by the CPUC.

Implications for Caltrain Level Boarding

Perhaps Caltrain already knew this all along, but this CPUC order implicitly relieves one of the key regulatory constraints to platform heights and level boarding, discussed numerous times in the past 15 years of this blog. It turns out that no waiver of GO 26-D section 3.4 is ever needed.

It may take a year or two before Caltrain finds out the hard way why they need level boarding, but this is a positive development. For that, we have the San Bernardino County Transportation Authority to thank.