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| Arrow level boarding platforms at San Bernardino, CA |
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.
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| Current Caltrain platform standards |
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.
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Why California needs a different platform standards in a first place? Does freight cars start magically swaying harder, once they are transferred from CSX to UP?
ReplyDeleteIt makes me super curious about how this compares with loading gauge clearances mandated elsewhere in North America (because, like, this is clearly so far clear of the static loading gauge, and I can't imagine the definition of the dynamic loading gauge itself allows *that much* lateral movement).
DeleteThe large clearances are mostly about crew riding on the side of freight cars.
Delete@XAN
DeleteEmployees riding on the outside of the cars like the old days is a factor as Clem notes, but another factor is oversize loads. Although loading gauge for railroad cars in N America maxes out at 10’-8” wide (3251 mm), rail is sometimes used to carry wider loads. For instance, the DoD requires certain rail routes from major bases to embarkation ports to maintain enough clearance for special 12’ wide flatcars to allow rail movement of large equipment like tanks. I’m not sure California has "different" standards to begin with; while I don't know about other carriers, Union Pacific considers loads up 13’ to be normal (7’-6” from CL) and wider loads require special clearance and charges (there are also limits for height, weight, center of gravity, etc.) Note that the CPUC rule is just about platforms but all railway clearances, and platforms are actually less restricted; the general side clearance for objects above the rail is 8'-6".
At the extreme level, for the largest/heaviest loads there are neat special cars called Schnabels which are just two large collections of trucks with a bridge section in between them. The bridge separates in the middle splitting the car into two halves, and then the load is suspended between the bridge sections (in effect the load itself becomes the middle part of the car, joining the two ends; large loads like transformers and chemical reaction chambers will be designed at the factory to have the required connection points for the Schnabel built into their structure). For the widest/longest loads the train will travel as part of a convoy with work crews ahead of the train dismantling and lowering things like lineside signals to allow the load to pass, then other crews behind the train putting them back up.
Of course, all of this is irrelevant to Caltrain, as there is nothing on the Peninsula that would ever require rail freight wider than standard loading gauge (or almost any rail freight at all for that matter). In general though, while I’m sure most people on this blog will be excited at the CPUC ruling, I’m not sure that a standard of ADA-platforms-always-take-precedence is good policy. Caltrain’s current Bombardier BiLevels, also used in LA, are only 9’-10” wide. It is conceivable with this ruling that Metrolink in LA could sever the Port of LA/Long Beach from the national rail network by installing level boarding platforms on the San Bernadino Line that wouldn’t let standard freight cars pass. Despite the animosity towards freight rail companies by transit advocates, freight rail is an extremely valuable service that shouldn’t be at risk from disruption like this.
The solution is a nationwide standard for mainline passenger railcar loading gauge (width and platform height, minimum). The 10’-8” width of AAR plates is the obvious choice along with the 48” high platforms of the NEC; the current 10’-6” width of EMUs in use around NY or Amtrak equipment would be fully compatible as it would mean only an extra 1” gap to the platform on either side. This would allow level boarding on any line use for passenger service without affecting standard freight use or requiring extra expense like the fold up/down platforms on the Sprinter Line. It would allow intercity and commuter services sharing the same line to have level boarding at the same platforms, and would also allow a train ordered for one service to be ordered by another operator for competition and economies of scale. There should be no reason for Caltrain to order a hundred or so bespoke railcars when thousands of M9s and Silverliners are in service every day. Conversely if Caltrain does order a higher quality product like FLIRT/KISS, then SEPTA, LIRR, etc. should be able to place their next order as more of the same, instead of opening a design competition for a modern EMU sized slightly differently for their platforms.
@Anonymous Metrolink implementing level boarding on the San Bernardino line would not "sever the Port of LA/Long Beach from the national rail network." The San Bernardino line has no through freight traffic, only a limited number of local services. The only lines where this would be an issue would be on the 91/IEOC/OC and Riverside lines, the former of which has extensive sections of third track or projects planned to add additional (third or fourth in some cases) tracks that could easily be used for wide loads. Should Metrolink ever care to increase service on the Riverside line similar treatments could be made (and would likely be required by UP regardless of level boarding).
DeleteAlso, Metrolink could probably use trains that are just as wide as whatever maximum-oversize-cargo-wagon size limit there is.
DeleteCompare with for example the S-train network in Copenhagen, where the cars are 3600mm wide, which is way wider than regular trains in Europe.
Might of course cause problems on platforms / stations shared by other trains, but still.
@Nick, you are correct, I meant the Riverside line, but had it in my head that it went to San Bernardino even though it doesn't get quite that far. The point remains however. The issue isn't a third track to carry occasional extra-wide loads, but that level boarding for Metrolink's Bombardier BiLevels would prevent NORMAL-width loads from passing (AAR plates C, E, F, which are 10" wider than the BiLevels). There is too much freight traffic to assume it will all fit on a third track while leaving two tracks dedicated to passenger trains.
Delete@MiaM, trains as wide as overside cargo are not practical. The extra wide Copenhagen trains (3600mm) or Russian trains (3400mm) are still narrower than the DoD equipment width (3657mm) or UPs overside cargo lower limit (3962mm). Trains that wide are probably not feasible on standard gauge track for stability reasons at speed (Russian trains are on wide gauge, while oversize train loads move very slowly).
Effectively though, you are making the same point as me when I argue for a national standard for train car width and platform height. If train cars were all 10'-8" wide, as per standard AAR Plates, then a platform that clears the commuter/intercity train clears almost all cargo trains. The wider-than-normal loads are not often brought directly into cities, and the few areas where their paths regularly follow lines with passenger service is where third tracks or gauntlet tracks would be appropriate.
I don't think 1520mm v.s. 1435mm makes that much of a difference. Also the Copenhagen trains is about two inches wider than the DoD width, not something that would affect stability.
DeleteWe are in agreement that a national standard would be great.
How much of the oversize freight needs to be able to be over size relatively low down near track level? Could the loading gauge be altered so oversize freight is only over size above a reasonably high platform level?
An example from Sweden, below 1200mm above the rails the loading gauge only allows about 3000mm wide trains, but above 1200mm the loading gauge allows wider trains. (This is for regular trains, oversize trans can run with special permits on certain lines). Sorry that the text is in Swedish, the picture should be intelligible even without the text.
https://www.greencargo.com/boka-transport/godsvagnshandboken/lastprofiler/sverige
Btw, it's "unfortunate" that regular trains may be wider than double the track width. If they were narrower then it might had been possible to lay the rails of a double track railway in a way that the two center rails of the four rails could be used for over size trains (with the railway operating in a single track configuration). In practice I would think that this would probably only work on concrete slab rails as it would otherwise likely crush the ties...
If we need extra width for wide freight trains, why can't we just make the passenger vehicles wider to fill that gap and have level boarding?
DeleteIf freight trains require 12 feet width, then make passenger cars 11' 8", so we have a 2" gap to the platform.
Could Caltrain implement level boarding at select stations to get momentum for the future? I know it would be weird but the trains have 2 door heights installed so why not start making some stations higher? For example they could start with the local stations like San Antonio, California Ave, Santa Clara, Hayward Park, and Broadway which will need retrofits or rebuilds anyway.
ReplyDeleteThis issue is technically quite a bit more complicated than first meets the eye. The entire fleet of EMUs would have to be retrofitted before the first platform could be raised.
DeleteScenario A: with high platforms, the upper door plugs would be replaced with the original high door design including a bridge plate mechanism, and new interior wheelchair lifts would need to be installed and cleared for use while the train is underway (currently prohibited by ADA) to enable boarding/alighting at different platform heights. While the EMU design has all the structural and electrical hooks to allow this, Caltrain staff doesn't appear to favor this approach.
Scenario B: with lower level boarding platforms favored by Caltrain staff, the lower door drop-step mechanism would need to be retrofitted for compatibility with level boarding platforms, which the current design is not. Right now, it can only dock at 8 inch platforms. The entire EMU fleet would need to be retrofitted before the first platform can be rebuilt to 22 inch height (550 mm Euro standard).
With either approach, there is a lot of investment required before the first platform can be rebuilt to provide level boarding. Important decisions need to be made and resources need to be found and allocated. I've been pushing on this string for well over a decade!
For Scenario B, the cost to retrofit the EMU fleet for level boarding is estimated at $31M and is part of the DTX/Portal budget as it is necessary for Caltrain to serve the level boarding platforms there. If that's an accurate estimate it doesn't sound too bad in the scale of these things.
DeleteThe interior lifts have to be certified for 800 lbs, not 600, and Caltrain cut a change order to Stadler to make the structural mounting points compliant to that requirement. It's already baked in.
DeleteIf another technical workaround can be found for the transition period (when some station platforms are raised and others not), then in the high platform scenario the bathroom would just be deleted if it causes accessibility mayhem under ADA regs. With no bathroom and all high platforms, you don't need any interior lifts to provide equal access. Problem solved.
Sunk cost fallacy alert! The insane internal lifts may be baked in structurally, but that in no way means that such high-service-impact high-maintenance-cost low-reliability one-off bespoke gadgets need to be or ought to be installed, ever. Just buy some high-floor toilet-toting trailer cars in the counter-factual world in which high platform level boarding comes to Caltrain -- it would be a rounding error cost, even if fleet replacement weren't necessary before then. Even if large parts of world weren't under water by then.
DeletePS Caltrain has never needed bilevel trains anyway, it's "just how we do things", and regardless of the low capacity of the badly configured Caltrain KISSes. One single-level car per train isn't going to hurt anything. Should've just FLIRTed (... and done the FLIRTing 19 years ago, when Stadtbahn Zug was a huge eye-opener.)
"High-floor toilet-toting trailer cars" sounds a lot more expensive than just closing all train bathrooms and installing JC Decaux style self-cleaning toilets at all stations. If you can't put a toilet on the train without having 800 lbs interior lifts to provide ADA equal access, then maybe there shouldn't be a toilet, period.
DeleteThe Decaux toilet is like an AI startup. The company claims it is "self-cleaning" but in reality it requires tons of maintenance by humans. And based on how much SF spent on building a standard public toilet, the high-floor toilet car is probably less expensive.
DeleteNote that an 800lbs doesn't have a weight of 800lbs, it's just able to lift 800lbs.
DeleteI would say that as for disability access 800lbs is reasonable as that is reasonable for a heavy person combined with a battery powered wheel chair that is actually usable on not-that-even surfaces outdoors (i.e. wheels like mini versions of those of a wheel barrow rather than the classic wheel chair with two bicycle style rear wheels and two tiny shopping cart style front wheels).
Re toilets - just have an extra toilet at whichever floor level ends up being the correct height for ADA compliance.
I would say that it seems like a not great idea to have toilets in the same cars as drivers cabs. Eventually over the years there will be some incident where poop smell fills the driver compartment.
Btw if anyone thinks that stupid things only happen in certain parts in the world, I can tell you that there was an incident where a class Y2 trains (diesel rubber nose trains that run i Sweden, iirc the same type also runs somewhere in Denmark. They look similar to the electric X31K/ET trains that runs on the bridge connecting Sweden to Denmark) had a sewage tank that overflowed. Turns out that if they overflow, they overflow inside the passenger compartment rather than through some emergency overflow pipe to the outside. And in particular they overflow inside the walls and whatnot. They ended up having to refurbish a lot of the interior of that car...
Btw while I'm at it telling stories about that train type: A sad accident that one of those trains were involved in, iirc a crash with a road vehicle at a level crossing, resulted in the drivers compartment being damaged (and IIRC the driver didn't make it) and the result was that the close-door-signal from the drivers compartment ended up fighting with the emergency door opening feature. Can't remember the details but I think that either someone had to hold the emergency opener or the fire brigade staff had to prop the doors open in order to let passengers exit the train. Can't remember if there was a diesel fueled fire too or not. The point of telling this story is kind of to make everyone aware of the conflicting demands of staff being able to lock the doors and passengers being able to emergency open the doors.
I had forgotten about this. Caltrain staff are currently conducting their "Level Boarding Roadmap" study, which is due for completion June 2025. Hopefully they are aware of this ruling. Perhaps a field trip to San Bernadino is in order for them to see what California-legal freight-compatible level boarding stations with modern Stadler MU rolling stock look like.
ReplyDeleteOf the stations currently being designed, Transbay and 4th/Townsend are planned to be level boarding already. Broadway should absolutely be designed for level boarding too, although I am not convinced that station should be rebuilt at all. The Redwood City plan seems to be dead for now since the new property owner for Sequoia Station has pushed back redevelopment at least 10 years. I don't think there are any other station rebuilds currently planned until 4 track stations are built for HSR overtakes (if that ever happens)
Thank you for finding it!
DeleteOr Caltrain folks could take a trip to Salt Lake City and observe level-boarding into the same Bombardier Bi-Level cars as Caltrain still has...
DeleteThe lateral gap at Salt Lake City's FrontRunner platforms is not ADA compliant, despite the matching heights of the platform and train floor. FrontRunner still uses bridge plates manually placed by a conductor to board wheelchairs. This does not help to make dwell times short and predictable.
DeleteCaltrain needs assistance-free level boarding, with no crew intervention. This requires a different technical solution than they currently have on the new EMUs.
Interestingly, Google's spam filters appear to act retroactively whenever they are updated, so legit comments end up in the spam queue for no reason well after they are posted... will have to go unclog that one by one, ew
ReplyDeleteWhat's new is that no "phone call" or "letter" is required at all. The CPUC's Rail Safety Division itself disavows section 3.4.
Look for California High Speed Rail (a fictitious entity, and a wholly owned subsidiary of WSP) to completely kneecap any hint of level boarding on "their" corridor and keep Caltrain operations and reliability resolutely in the 1940s.
ReplyDeleteThose grifters and clowns (the same ones who have "designed" their own globally turnouts!) have pulled a feet-and-inches "standard" out of their rectums, and Caltrain Must Comply. Now what these "standards" are are in fact TBD, "Station Platform offsets and elevations will be specific to the equipment operated. Since the type of equipment is unknown at this time, the platform edge location specific to the CHSTP can not be finalized" so you can bet that the merest hint of a threat of level boarding for Caltrain is decades away. I mean, who is in charge here? Can't be too hasty!
What the rent-seeking grifters do suggest is "the widest trainset is the Shinkansen with 11.09 feet, making it necessary to clear 5.75 feet" (that's 1752.6mm, weird and bespoke, but of course it add cost, so that's double-plus good, plus *somebody* got paid tens of millions of US Dollars to translate global standards into feet and kips and slugs and fahrenheits and then ... ignore them all and pull stuff out of their rectums) but ... at a TBD elevation above top of rail. (Hey at least they didn't ignore the entire Asian world, the actual leaders in global HSR, this *one* time! Probably only because US consultants imposed themselves on Taiwan HSR, else they'd have blown off that entire hemisphere of the world.)
All the (non-mini) Shinkansen derivatives (including China HSR's) are 3.380mm wide, which means half-width of 1609mm (5.545 feet in clown units) which means we're talking at 143.6mm (5.65 inch) platform-train gap between TBD-we'll-get-back-to-you-some-decade CHSR "standard" platforms edges and the effective global standard HS train design. So gap fillers to get down to the ADA limit of 3 inches are going to be required on fictional far-future CHSR trains, or ... the platform "standard" will be revised, hah hah joke's on you!
But it's worse for Caltrain! Far worse! Even leaving aside the high-platform/low-platform nonsense, bear in mind that Caltrain specified 3000mm wide KISSes (Caltrain *could* and *should* have gone with 3.4m-ish wide Shinkansen-ish wide trains, but of course didn't and just copied that dimension from the old unpowered Bombardier unpowered cars) so boy howdy is there train-platformd gulf width to bridge, regardless of the height above rail.
752.6mm - 3000mm/2 - 3inches = 176.3mm (6.94inch) *minimum* gap filler, and a nice PLEASE PLEASE SUE US RAW FOR THE INEVITABLE ACCIDENTS 252.6mm 9.94in hole between the platform edge and the train side. Just picture it!
One can safely bet that "safety", in full irony!!!, is going to be trotted out as a reason Caltrain can't have level boarding until after the CHSR tooth fairy comes to town *and* until after the KISS fleet has been retired.
Same old same old never ever not ever we've been seeing for three decades and counting.
I think the nose of the gap filler step (automatic bridge plate) on the EMU high doors is at about 70 inches from the car center line, although I don't have it to the millimeter. If anybody knows, please specify. These are large steps that were specifically designed to reach just outside the CAHSR composite dynamic envelope, and would be compatible with a 72 inch platform lateral offset. The people who engineered this did their homework.
DeleteYou do need a big gap: you'll never get airport people mover gaps when you need to operate an express at 110 mph (ultimately 125 mph?) past a platform.
Also, the new ADA lateral gap is 2 inches, per guidelines issued by the Access Board’s Rail Vehicles Access Advisory Committee. This is not yet federal regulation but must be designed to because it soon will be.
Big pants engineers can use any unit, although they may sometimes crash spacecraft into Mars as a result of unit conversion errors.
Two important updates for Richard. WSP is out (or shortly will be), and CAHSR will be using gap fillers that is the plan.
DeletePassing through stations at only 125 mph? How quaint. IIRC, platform gaps on the Shinkansen are more like 2 to 4 inches, and they do check the track geometry far more frequently than would ever happen here. Station personnel are happy to provide small bridge plates for wheelchair users on request, not all use them.
DeleteNote also that the red/white train sets (as opposed to teal/white) in the paired sets are narrower Mini-Shinkansen that are designed to operate on the traditional narrow gauge (3'6") ROWs and platforms (some lines have been replaced with standard gauge, others are dual gauge) at reduced speeds (130 km/h). They have simple flip out gap filler steps for use at regular Shinkansen stations. The paired sets are decoupled at a station farther north so they can serve different destinations (in this case, Hakodate and Akita), then coupled on the way back to Tokyo to increase throughput.
DeleteMarc, that Mizusawa-Esashi video is quite something. Thank you! (Says some pahtetic loser who made a pilgrimage to TGV Haute-Picardie some time in the 1990s or early 2000s for something much less impressively fleeting.)
DeleteA few comments:
ReplyDeleteIn general, for everything idiotic with Cali HSR and Caltrain and whatnot that can easily be proved, maybe write a way more nicely worded mail to the Youtuber Alan Fisher and see if he might be interested in making a video about it? Another possible candidate might be Not Just Bikes but he seems to not be that interested in the details. Both of them are relatively large urbanist Youtubers that actually aren't afraid to say that something is crap when it's crap. It might be worth a try with the other rail/urbanism Youtubers too, but I doubt that they would want to delve into all the many small but important details and make a video that is mostly negative.
Re Cali HSR trains: Afaik they will kind of go for whatever Brightline West chooses, as they want compatibility and Brightline West needs to have trains delivered sooner than Cali HSR. This might be a reason for why Cali HSR use blurry wordings re platform specs and whatnot.
In general re train width: It's worth knowing that the width at platform level might be narrower than the max width higher up. Not super common but there sure are trains built that way. A few examples are the "Regina", class X50...X55 trains in Sweden, where the regional train version has 2+3 seating that is as comfortable as 2+2 seating in most other trains. Another example is the regional trains between Denmark and Sweden, class X31K/ET (X31K = Swedish class, ET = Danish class) that in contrast are a pain to ride in for longer trips, but still has narrower width at platform level than higher up. In particular the seats next to the windows would likely only be comfortable for a person that had a leg amputated, in particular the one next to the window, as there is kind of only room for one leg at each window seat... Anyhow, the X50...X55 class is 3450mm wide, wider than the Shinkansen derivatives you mention, but that is above platform height.
Btw, re the other comment with a sign telling staff to not ride on the outside of cargo wagons: This is 100% an excellent example of the English speaking worlds obsession with using words rather than symbols. Sure, similar texts might be found elsewhere too, but in general that type of sign would be either a round sign with a cartoon style drawing of someone riding on the outside of a wagon, with a diagonal red line across it, indicating that it's prohibitet. Or it would be a triangular sign with a cartoon style person getting their limbs chopped off due to missing clearance. Takes way less time to interpret such signs and in particular you can to some extent see and interpret/understand the signs even if they are in your peripheral vision, something that hardly anyone can do if it's just written text.
At least two people in this conversation made this video over 15 years ago to suggest what could be done to improve the DTX. Response was jack shit. And I like Alan's work, but this is technical way beyond his usual work. Reason isn't the answer, sadly.
Deletehttps://vimeo.com/499863859
alan fisher is a median foamer who repeatedly defends the excesses CAHSR because we spend money on highways too. if you gave richard a producer and an anger translator that'd only get you like one sigma beyond the autists who gather here
DeleteMichael:
DeleteSeems like that video is age restricted, asks for sign in :/
spiral:
Alan Fisher may be many things, but in particular I would say that he is the largest or at least one of the largest Youtubers that both seem to actually understand various technical details at least on the level we are discussing here, and also isn't afraid about speaking up against things that are done wrongly.
I'm absolutely not saying that he is perfect in every way. Just saying that let's not make perfection become the enemy of good.
Apparently SMART didn’t get the ADA GO-26D override for level boarding CPUC memo either: Watch them build another gauntlet track for their new North Petaluma station.
ReplyDeleteLTK Engineering Services FTW
DeleteSMART is offering freight services so they need the gauntlet tracks for freight to pass the stations.
DeleteADA only preempts CPUC regulations when there is no freight traffic, per 49 CFR 37.42(b)
Maybe they had already hired contractors to do the job, and changing things might had cost just as much as continue with the plans?
DeleteAlso since SMART already has gauntlet tracks everywhere which solves the problem, albeit at the extra cost of maintenance of switches and whatnot, they might not be that keen on the possibility of becoming a pilot legal case against some freight operator.
On the other hand, Arrow relies on this interpretation of the rules for all of their stations (as I understand it) so have way more incentive to actually take a legal battle with any freight operator that might challenge them.
@Anonymous: you seem confused. §37.42(b) is irrelevant as it merely requires level boarding at new or altered stations where there is no freight on platform-adjacent tracks.
DeleteIt does not, however, preclude an operator from providing ADA-compliant level boarding despite having freight on platform-adjacent tracks, as both SMART & SBCTA do.
The whole point of this post was that SMART’s gauntlet tracks or other nutty stuff like Sprinter’s fold-away platforms are no longer required for CPUC’s GO-26D compliance on platform-adjacent tracks with freight when providing ADA-compliant level boarding for passenger trains.
@MiaM SMART owns the freight railroad that operates on their tracks, so a lawsuit would seem exceedingly unlikely (unless they wanted to sue themselves for some reason).
Delete"ADA only preempts CPUC regulations when there is no freight traffic, per 49 CFR 37.42(b)"
DeleteAh, ha, this seems to be an exceedingly key point. If Clem was aware of this then he is burying the lead.
@Reality Check, §37.42(b) seems to be exceedingly relevant. The CPUC ruling was that the ADA preempts state law. You are correct that §37.42(b) does prevent level boarding next to tracks with freight, but if it doesn't require it, then there is no preemption ("I don't prohibit it" =/= "I require it") and the CPUC could absolutely enforce GO-26D.
Of course one could argue if Caltrain tracks really have freight traffic. This of course is another reason why Caltrain should have kicked UP off of their ROW years ago (or at least gotten major concessions - exemption from GO-26D, buy the ROW from Tamien to Blossom Hill - in exchange for not closing the Peninsula to UP).
@Nick:
DeleteOh, well, that settles it. They probably did a cost-benefit analysis and opted for gauntlet tracks then.
37.42(c) explicitly says that level boarding next to freight tracks is an option.
ReplyDeleteHowever, it is not a mandate so it would not override the CPUC GO
I interpret it as follows:
No freight-->37.42(b)-->level boarding is federally required-->CPUC irrelevant
Freight exists-->37.42(c)-->level boarding not federally required-->CPUC still applies
This is exactly how I would interpret it, and it would mean that despite how Clem frames this post, GO-26D is still applicable in California and that level boarding is not by-right for passenger operations.
DeleteIf you read on to section (d), the FTA/FRA has to approve requests for projects that lack level-boarding. In the case of the Roanoke, VA Amtrak station, the FRA denied a request for low-platforms -- even though it had freight traffic.
Deleteper Wikipedia, Arrow time-separates freight and passenger operations. BNSF run "low-volume freight" for "a few customers" in overnight hours. Maybe BNSF is easier for Arrow to deal with, than UP is for Caltrain?
DeleteBut CPUC did not exempt them, they just said that the GO is preempted:
ReplyDeleteFinding 1: "Because the ADA preempted Section 3.4, no exemption is needed for this particular provision."
If there is indeed freight passing through the downtown SB station, then ADA should not have preempted CPUC here.
If is notable that the word “freight” (or any allusion thereto) appears nowhere in the 5-page background discussion or enumerated findings of the May 6, 2022 CPUC Resolution #ROSB-005 ”granting an exemption from GO 26-D.”
ReplyDeleteOne would think that if CPUC’s exemption grant was in any way predicated on or related to the existence or non-existence of freight traffic past the higher Arrow FLIRT level-boarding platforms that that fact would at least be mentioned.
And time-based separation from freight has only to do with collision avoidance — and so is irrelevant to platform or other clearance issues.
It is strange that freight is not mentioned when it seems relevant, but I think it's worth clarifying what is and is not being exempted here.
DeleteThe exemption granted is only related to sloped walkways, not to platform itself.
"An exemption from General Order 26-D, Section 3.2 is granted at SBCTA’s four new stations planned along the Redlands Passenger Rail Project line for the limited purpose of installing gradually sloped walkways to ensure that a walkway is provided at the end of the ADA-compliant platform for the safety of railway workers, in compliance with General Order 118-A."
The exemption is granted for the sloped walkways. They don't _need_ an exception for the level-boarding platforms, as the ADA (federal law) requirement for level boarding (equal access) _preempts_ the 1948 California state regulation. See Clem's link under 'preempted". US Constitution, Article VI, clause 2.
Delete