30 March 2024

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.


  1. 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?

    1. It 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).

    2. The large clearances are mostly about crew riding on the side of freight cars.

    3. @XAN
      Employees 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.

    4. @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).

    5. Also, Metrolink could probably use trains that are just as wide as whatever maximum-oversize-cargo-wagon size limit there is.

      Compare 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.

    6. @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.

      @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.

    7. 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.

      We 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.

      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...

    8. 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?

      If freight trains require 12 feet width, then make passenger cars 11' 8", so we have a 2" gap to the platform.

  2. 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.

    1. This 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.

      Scenario 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!

    2. 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.

    3. The 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.

      If 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.

    4. 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.

      PS 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.)

    5. "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.

    6. The 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.

    7. Note that an 800lbs doesn't have a weight of 800lbs, it's just able to lift 800lbs.

      I 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.

  3. 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.

    Of 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)

    1. Thank you for finding it!

    2. Or 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...

    3. The 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.

      Caltrain needs assistance-free level boarding, with no crew intervention. This requires a different technical solution than they currently have on the new EMUs.

  4. 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

    What's new is that no "phone call" or "letter" is required at all. The CPUC's Rail Safety Division itself disavows section 3.4.

  5. 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.

    Those 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.

    1. 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.

      You 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.

    2. Two important updates for Richard. WSP is out (or shortly will be), and CAHSR will be using gap fillers that is the plan.

    3. Passing 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.

    4. Note 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.

    5. Marc, 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.)

  6. A few comments:

    In 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.

    1. 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.


    2. idiot doom spiral02 April, 2024 23:02

      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

    3. Michael:
      Seems like that video is age restricted, asks for sign in :/

      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.

  7. 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.

    1. LTK Engineering Services FTW

    2. SMART is offering freight services so they need the gauntlet tracks for freight to pass the stations.

      ADA only preempts CPUC regulations when there is no freight traffic, per 49 CFR 37.42(b)

    3. Maybe they had already hired contractors to do the job, and changing things might had cost just as much as continue with the plans?

      Also 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.

    4. @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.

      It 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.

    5. @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).

    6. "ADA only preempts CPUC regulations when there is no freight traffic, per 49 CFR 37.42(b)"

      Ah, 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).

    7. @Nick:
      Oh, well, that settles it. They probably did a cost-benefit analysis and opted for gauntlet tracks then.

  8. 37.42(c) explicitly says that level boarding next to freight tracks is an option.

    However, 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

    1. 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.

    2. If 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.

    3. per 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?

  9. But CPUC did not exempt them, they just said that the GO is preempted:
    Finding 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.

  10. 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.”

    One 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.

    1. 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.

      The 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."

    2. 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.

  11. While looking at the Executive Director's April Monthly Report, one may notice an interesting statistic: 2,224 minutes of train delay last month were due to vehicle or pedestrian trespassers onto the right of way, while only 51 minutes were due to bike loading/unloading and 86 minutes were due to wheelchairs. Does this provide evidence that grade separations are more important for reliability than level boarding?

    1. Apologies, the data is from March, not April.

    2. Interesting perspective. Looking over the past several months, it does seem that vehicle/pedestrian "trespassers" are consistently the largest source of delay. It wasn't a one-off for March.

      I wonder how many of those "trespassers" were motivated trespassers who might make it onto the tracks even with grade separations, and how many are more accidental. It is primarily the accidental situations - say, a car turns onto the tracks - that grade separations could prevent.

    3. Broken down into suicide (unavoidable) versus "accidental" motor vehicle intrusion and you might have some data about something. But they don't and won't break things down this way, however, for various reasons, most particularly including extreme and decades-long antipathy to reliable operations.

      But that's besides the point. Looking at the current Caltrain timetable, one can see it can be pretty well modelled in Ye Olde (15+ years old) Taktulator using 20+% (Over TWENTY PERCENT. ¡¡¡ >TWENTY PER CENT!!!) timetable padding and with 40+ second station dwell times. (Actually, it is worse than that: some "rush hour" trains operate with over 25% padding, while the "rush hour" express, the one bullshit train per hour that Caltrain has based the entire last 25 years of its "service" around, has 60 second dwells at every single stop.)

      Anyway, EACH AND EVERY WEEKDAY, Caltrain is losing 1763 minutes of service time to the decades of failure of its shit staff and shit contractors to implement, let alone plan for, level boarding.

      1580 stops/day * 40+s vs 20s dwell time = 527 minutes of delay per weekday, every weekday of the year; plus 9508 revenue minutes/day padded at 20+% vs at achievable 7% = 1236 minutes of delay per weekday, every weekday of the year.

      So Caltrain inflicts 80% as delay on its passengers every single day of the week as it bleats about from a month of "trespasser" delays.

      It can't be said strongly enough that by far the single most cost-effective thing that could be done to improve and all of Caltrain capital costs, Caltrain operating costs, Caltrain operating efficiency and/or Caltrain service levels is to fire every single person who has ever worked for the agency or contracted or the agency, and preferably prosectute the worst of them, those resposible for billions of incinerated public cash.

      It really is that bad. It's happening every single day, and it's been going on for decades, and nobody gives a fuck because you can produce some shit report about "trespassers" being the excuse for your shitty, slow, LOUD, unreliable, infrequent and expensive "service".

      Orders of magnitude, people, orders of magnitude.

    4. Reality Check03 May, 2024 10:57

      Going back for decades, Caltrain pedestrian “strikes” (10 already so far this year, all fatal) are essentially all intentional acts (I defy anyone to cite truly accidental ones).

      As a review of forward facing video recordings revealed, the last one was a 39-year-old man who ran out and put his head on the track at the last moment in front of an oncoming express train at the Cal Ave. station in broad morning daylight.

      It’s such a lonely station that it wasn’t even noticed until the next stopping SB train (2 whole trains later!) stopped short and reported a body on the track.

      3 of this year’s 10 have been at Cal Ave., and 3 others were also at/near stations and well-away from grade crossings (e.g San Carlos).

      So while costly disruptive grade separations with their shooflies — now costing up to $1/3 billion each (Broadway Ave. in Burlingame) — will do nothing to stop suicides, they will at least only stop the 5 - 6 monthly nighttime vehicle incursions onto the ROW and any other truly accidental driver fuck-ups.

    5. The way to get tax payers attention to the delays caused by non-level boarding is to simply calculate an equvalent of train sets and accompanying staff that Caltrain could do without if they had level boarding

      Re train-people/vehicle collisions: Level separation still helps as it makes it way harder for people to trespass on the rails far away from stations. Near station a combination of CCTV (that is actually not just recording but also viewed by humans, for example where the dispatchers are located) in combination with presence detectors (like those used to automatically turn on the light when someone is in the vicinity) can be used to detect trespassing people (and possible wild animals, if there are any such in the Caltrain area).

      Also, if someone decides to on purpose be ran over by a train, it's way more avoidable if it happens near a station where the train will stop anyways as the likelihood of the train being able to brake increases. If this becomes a big problem at stations the track area could be filled with something that makes it similar to street running tracks and the trains could have plows fitted (unless they already have) that most likely just throws trespassers to the side rather than running them over. Still a collision would cause delays, but there is a great difference between having to carry a body away from the side of the tracks and wash the exterior of a train, or to dig out body parts from underneath a train.

      As a side track, this might be a case where AI might actually be useful. I.E. AI interpreting live CCTV feed predicting if someone that acts unexpectedly seems to just be a general weirdo, a train enthusiast, a criminal in general or someone likely to jump in front of the next train.

    6. Reality Check05 May, 2024 03:59

      MiaM: you sound very young and/or naïve.

      Please cite where & how the potential for O&M cost savings has ever “moved” disaffected US “tax payers,” and where their being “moved” somehow, magically, subsequently caused an insular rail transit agency like Caltrain to do anything (let alone a huge systemwide multi-million-dollar years-long capital project) to realize those savings?

      Please also cite examples of where & how any of the suicide prevention measures you propose were implemented and measurably reduced (let alone stopped suicides).

    7. "Reality Check" - please don't be so condescending.

      Removing ways for people to commit suicide is proven to lower the suicide rates. Having sealed and grade separated corridors will go a long ways towards reducing the suicide rate (and the accidents / car incursions). Reference: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3290984/

    8. Reality Check06 May, 2024 13:02

      @Anonymous: Thanks for that 13-year-old hand-wavy literature review matching a selected set of search terms. (Did you actually read it?) It reads like an advocacy piece in which the authors set out to (or were assigned to) try to bolster a pre-conceived conclusion … which they didn’t, and so necessarily had to pepper their narrative with 28 uses of the word “may.”

      While there was not single reference to train / RR suicides, remember that removing some or even all grade crossings would not be the sort of significant means reduction that the paper is focused on.

      Unlike the world’s grade crossing-free systems (like BART) that also struggle with suicides despite having staffed stations, fare-gates, monitored CCTV cameras, and no express trains, Caltrain line has completely open, barrier-free, unstaffed, easy-to-access, low-platform stations about every 2 miles, on average.

      People who develop the intent to die on the Caltrain tracks won’t have any trouble accessing the tracks for lack of a nearby grade crossing. It already appears they gain track access from stations in about the same proportion as grade crossings, so there’s no compelling evidence or reason to believe they won’t all just go to their nearby stations instead when there are no remaining grade crossings.

      But yes, obviously, grade separations will eliminate vehicle collisions and accidental pedestrian collisions.

      And sure, in a nod to the paper and its adherents & defenders, it’s possible that a grade separation would avert an un-premeditated suicide where someone just happens to have a fleeting thought to try die while at crossing with an approaching train.

      And as rarely seen on BART and Caltrain, some vehicle collisions may still occur when drivers crash through fences onto the ROW or seemingly deliberately jump the curbs and platforms at stations (e.g. the popular and renowned music professor and nearby Burlingame resident who drove his Porsche SUV onto the Broadway station tracks from the parking lot and remained inside to be hit & killed by two trains!).

      Lastly, remember in terms of reducing the suicide rate by all means, that trains represent minuscule <~1% of US suicides. So even if none of the Xing suicides shifted to join the others that already occur at stations, or to any other far more ubiquitously available & prevalent means, the all-means change would be immeasurably minuscule.

      Which brings us back to this: costly & disruptive Caltrain grade seps have obvious benefits & justifications, such as to reducing congestion and driver aggravation, eliminating vehicle incursions and accidental crashes … but stopping suicides is NOT among them!

    9. It the general public have never been outraged by O&M costs in the US, then you probably have and have forever had the shittiest journalists in the world.

      Come on, contact journalists and serve them the facts on a plate, with references to public documents from various places that a journalist will deem trustworthy. You might have to make it a thing where an interest organization or a bunch of general citizens are upset so the journalist have someone to interview and make it a "feeling and whatnot bullshit" thing, and also someone that they can put all the blame on if some facts are incorrect. Either way it will reach the goal of increasing awareness of the problem.

      Two important things re collisions due to people deciding to end their life, but also accidents and youngsters playing dare games and whatnot:
      As already stated, at stations the speeds of at least some trains are way slower which makes it more likely that the train driver will be able to brake enough to preferably avoid a collision or at least to mitigate the impacts of a collision. Also as already stated, CCTV with something that automatically alerts if it detects trespassers would also help.
      At level crossings and generally where there aren't any decent fencing the speeds will be higher.

      The other thing is that someone ending their life isn't comparable to most other decisions as it's a combination of a long term decisiveness to go ahead with it and at least some element of impulse to go ahead with it at a particular moment. Even if someone were for sure going to go ahead with it if a road-rail crossing they are at were a level crossing, it's not a given that they will go ahead with it at a future opportunity. Some minor or major detail might change, i.e. they might happen to hear their favorite song on the radio, a close friend might invite them on vacation thanks to said friend just won a a bunch of money on lottery or gambling, or any other things might change. Therefore taking away an opportunity actually reduces the risk of they going ahead with it.

      Thanks Anonymous for digging up a reference. If I had dug up a reference it would likely had been in Swedish so you'd have to attempt using some translation service. (I found some article, in Swedish, stating that approximately 10% of all road traffic related deaths are done on purpose. And sure, this is in Sweden which is world leading in road safety so the percentage of all deaths would most likely be way lower elsewhere, but still).

    10. Reality Check07 May, 2024 12:04

      While it may sometimes happen that way, people using Caltrain for suicide don’t just wait around on the track for a train to show up … especially in view of cameras or others that may derail their morbid plans.

      They may be suicidal, but they're generally not stupid … many are well-educated professionals and most show a bit of premeditation toward “successfully” achieving their goal.

      So, no, instead they typically simply await the approach of a train and step into its path when it’s too close to stop. Express, freight (and future HSR trains) will never move through stations slowly enough to prevent this. And as with subway systems around the world, even stopping trains enter stations too fast to stop in time if a person steps off the platform and into their path.

      The only way to stop train suicides is a sealed corridor with platform screen doors … something systems like Caltrain with simple outdoor suburban stations will likely and understandably never justify or do.

  12. The GGBA (Golden Gate Bridge Authority) tried to ignore suicides for a long time, but finally were forced to deal with the problem with a hardware solution. Putting nets under the bridge cost a lot of money, but the politics wouldn't let "kicking the can down the road" palatable anymore.