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.

Grade Crossing Trouble Ahead

Grade crossing in Denver (photo: RTD)

Denver's RTD has been operating a new 25 kV electrified commuter railroad since 2016. There's a big problem with it: the grade crossings gates are down for too long, which the FRA and Colorado PUC consider hazardous because impatient motorists frustrated by a longer-than-expected wait may drive around the gates just as the train finally shows up. The problem has festered, with  millions spent on human flaggers to supervise traffic at each grade crossing, contractual acrimony leading to lawsuits, and in recent days a threat by the FRA to shut down the entire railroad until the issue is resolved.

What does any of this have to do with Caltrain? The peninsula corridor electrification project uses the same electrification technology installed by the same contractor (Balfour Beatty), uses the same positive train control technology installed by the same contractor (Wabtec), must contend with more than three times as many grade crossings, and therefore, faces the same looming grade crossing problem. For months, the issue has topped the list of risks that threaten the project, and the search for a viable solution is causing the electrification contractor to fall significantly behind schedule.

How grade crossings are supposed to work

The simplest way to activate a grade crossing is for the train to shunt a track circuit at some set distance before the crossing. This is known as a conventional track circuit warning system, and doesn't work well if different trains arrive at different speeds. The point where the crossing activates must be set far enough ahead to give the required warning time before the fastest train arrives at the crossing; this makes the gates stay down too long for slower trains.

The usual solution to this problem is a Constant Warning Time (CWT) system, which uses electrical signals sent through the track to sense the distance and speed of the approaching train. The grade crossing controller can then predict when to activate the crossing such that the warning time is approximately constant regardless of train speed. This is the type of warning system installed today on the many grade crossings of the peninsula rail corridor.

The FRA provides a nice overview discussion of how various types of grade crossings work. The applicable federal regulations are under 49 CFR Part 234.

What happened in Denver

Because the Denver system is electrified, there are large 60 Hz AC traction return currents (at safe low voltage!) commonly present in the rails when a train is nearby. These currents interfere with and prevent the use of a traditional Constant Warning Time system.

The contractor came up with a "smart" solution: the crossings have a traditional track circuit warning system overlaid with a wireless crossing activation system (WCAS) that interfaces with the positive train control system. Software sends wireless messages back and forth between the train computer and the crossing controller. The train and crossing enter into a contract: the train predicts when it will arrive at the crossing and promises not to get there any sooner, and the crossing commits to activate at some fixed time interval before the appointed arrival, staying closed until the train passes. Depending on the circumstance, the train may arrive at the crossing later than anticipated when the contract was entered into, resulting in extended gate down time. When WCAS is inoperative, the old-school track circuit takes over, also resulting in extended gate down time when a train is operating at less than maximum speed.

In early 2016, before the Denver train opened for revenue service, FRA and PUC inspectors found that the crossings activation times were inconsistent, with frequent occurrence of long gate down times and erosion of what is known as "credibility" of the warning system. Things went gradually downhill from there:

• So as not to delay the much anticipated start of revenue service, the regulatory agencies granted a temporary waiver to allow RTD to begin operating without WCAS, on the condition that human flaggers supervise traffic at each affected crossing, at the expense of the contractor.
• The contractor tried to tweak the WCAS software to make warning times more consistent. A fudge factor known as the "Approach Condition Adjustment Factor" (ACAF, so known because every fudge factor needs an acronym to sound legitimate) was applied based on the observed statistical distribution of warning times at each crossing.
• In September 2017, the FRA gave RTD relief in its interpretation of the consistency required for gate downtime, relaxing its unofficial consistency criterion from +/-5 seconds or +/-10% of programmed warning time to +15/-5 seconds for RTD's system.
• Performance of WCAS failed to satisfy the increasingly picky regulatory agencies. RTD began to penalize the contractor for failing to deliver a working grade crossing solution. FRA inspectors kept writing up excessive downtime violations.
• The FRA forbade the start of revenue service on a newer rail line that has since been completed. The original plan to create quiet zones, where train horns are not used at grade crossings, was delayed indefinitely to the continuing aggravation of neighboring residents.
• In September 2018, the contractor decided that the regulatory agencies had invented and enforced new consistency requirements that were not in the official regulations, and sued RTD claiming "force majeure" of a regulatory change. The complaint makes a fascinating read.
• In October 2018, the FRA provided the latest inspection report (of many) showing continuing non-compliance with the -5/+15 second consistency tolerance.
• On November 15th, 2018, the FRA fired off a letter indicating that it was fed up with the continuing grade crossing non-compliance, among other things, and threatened to shut down the entire commuter rail system by revoking the 2016 waiver.
• RTD is lawyering up against the FRA, and submitted a strongly worded legal memorandum with numerous exhibits effectively claiming that the grade crossing problem exists solely in the imagination of the regulators. RTD provided evidence that other railroads (including Caltrain!) commonly experienced long gate down times in violation of the criteria imposed on RTD.

Whatever happens next is sure to be dramatic. The entire saga can be reviewed under docket FRA-2016-0028, which organizes all the documents exchanged between RTD and the FRA relating to the temporary operating waiver.

Some Observations

Measured distribution of 38255 grade
crossing activation times in Denver.

1. Denver solved the wrong problem. They tried to invent a better mousetrap, something more sophisticated than a constant warning time grade crossing predictor. All they needed to do was to provide the same simple function with a substitute detection method that didn't rely on traditional audio-frequency AC circuits, which are incompatible with electrification. Instead, they decided to invent a better mousetrap involving lots of software, GPS, and wireless messaging, which naturally attracted regulatory scrutiny.
    
2. Complexity is bad. Multiplying the number of interfaces and creating dependencies between elements of the system leads to expensive aerospace avionics-like hardware and software that is cumbersome to deploy, test and maintain. System complexity leads to a proliferation of strange and unanticipated corner cases and failure modes.
    
3. Software can anticipate when to activate a crossing and prevent a train from showing up too soon, but there is no software in the world that can make a train show up on time.
    
4.  Grade crossing activation times naturally follow a statistical distribution that arises from random environmental factors beyond the control of the warning system. The low end of the distribution must never be shorter than the mandated 20 seconds, but the long end of the distribution will inevitably have some outliers. The diagram above shows the measured distribution of 38255 crossing activation times on RTD. Notice the long tail.
    
5. Even traditional "constant" warning time systems have this statistical tail. If the FRA inspectors applied the same regulatory zeal to Caltrain as they did to RTD, Caltrain would certainly be found in non-compliance. This isn't idle speculation: RTD gathered the data to prove it.
    
6. The criteria for non-compliance, namely a "significant difference" from the prescribed warning time, are subjective. Guidance from the FRA acknowledges as much: "Thus, prudent judgment must be exercised when reviewing the results of warning time testing to determine whether the actual warning time provided during testing was compliant with the standard."
    
7. The regulators painted themselves into a corner. They imposed a strict -5/+15 second criterion, which is easy to verify for an inspector with a stop watch and a clip board, but makes the long tail of the activation time distribution an automatic violation that is almost impossible to avoid. In recognition of the environmental factors beyond the control of the warning system, the regulators should have used controlled test conditions or applied a different criterion, such as X% of activations within Y% of programmed warning time. This is harder to verify for an inspector with a clipboard, but the grade crossing controller ought to be able to maintain these statistical records across a very large number of crossing activations.
    
8. While electrification is relatively rare in the US, there are numerous railroads abroad that have solved the constant warning time problem in electrified territory. This probably isn't rocket science. The mousetrap already exists.

Lessons for Caltrain

With the grade crossing warning system already at the top of the Caltrain electrification project's risk list and the contractor falling behind, this problem is already getting a lot of attention. The people involved hopefully already realize:

Keep it simple - the job is to come up with a grade crossing predictor that works in the presence of traction return currents. It will be tempting to come up with a more sophisticated custom solution that uses lots of software, but we learned from the CBOSS project, and Denver's travails, that complexity usually leads straight to disaster. The dumber the better.

Document existing conditions - a large database of activation time statistics should be assembled for each crossing as it exists today, to head off a conflict over the subjective nature of the FRA warning time consistency criteria. In the event of a Denver-like disagreement with FRA or CPUC, Caltrain would be in a position to quantify precisely how much more (and hopefully not less) consistent the new warning solution will be, regardless of the selected criterion. Caltrain enjoys the advantage that it isn't building new crossings like Denver, so there is an existing system performance baseline that is already accepted by regulators. That baseline will only be useful if it is thoroughly documented.

Plant the goal posts firmly - Work with FRA towards mutually agreed verification criteria that don't repeat the mistakes made in Denver of specifying a rigid range and then testing in the uncontrolled conditions of revenue service. The activation time distribution will always have a statistical tail. If the consistency criterion can't be met by today's existing grade crossing system, then it's probably a bad criterion.

Make sure we aren't paying for Denver - the contractor needs to be held accountable for the extent to which Caltrain electrification funds (and schedule delays!) are accruing to the Denver project's benefit, if the same grade crossing solution is ultimately pursued in both projects.

UPRR Leaves, Sort Of

Caltrain and Union Pacific have recently agreed on the terms of a deal for UPRR ceasing to operate freight trains on the peninsula, between Santa Clara (CP Coast) to San Francisco. This is not the end of freight, however. The Deal Terms Sheet (2MB PDF) outlines the process by which a smaller "Short Line" operator would take over the rights and obligations to continue serving rail freight customers on the peninsula. It also unravels a laundry list of contentious issues that pitted UP and Caltrain against each other. In summary, there are three phases to the deal:

1. The agreement recently entered into by Caltrain and Union Pacific, stipulating that:
• UP will start looking for a new short line freight service provider.
• Caltrain will ensure that short line locomotives with freight PTC can operate throughout CBOSS territory, a condition described as "unconstrained interoperability," a great pretext for more CBOSS program blowouts
• Caltrain will ensure that Caltrain rolling stock can operate on UP's freight PTC equipped Gilroy branch, or cease operating on the Gilroy branch.
• Caltrain agrees to never electrify UP's Main Track 1 from CP Coast (Santa Clara) through San Jose to CP Lick (south of Tamien), the land under which Caltrain owns.
• UP agrees not to object to the CPUC safety requirements (1.4 MB PDF) formally adopted on 10 November 2016 for Caltrain's electrification project.
• UP allows Caltrain's SSF station reconfiguration project to proceed, trading some old yard tracks and a loading dock for $2 million plus a new Caltrain-funded freight yard track at Newhall in Santa Clara.
• UP settles some old claims by Caltrain for track maintenance.
   
2. In the coming months, 
• UP will select a Short Line and obtain Caltrain's approval.
• Caltrain will sign a new trackage rights agreement with the short line.
• Caltrain will sign a new trackage rights agreement with UP that replaces the current trackage rights agreement, concerning the "South Terminal Area" around San Jose.
• The Surface Transportation Board will hopefully approve the whole deal, which is the entry criterion into phase 3.
   
3. Upon STB approval,
• Caltrain will own the "common carrier" obligations and be on the hook legally and financially for abandonment of freight service, should that ever be contemplated.
• The Short Line will own the common carrier obligations on the sidings and lead tracks not owned by Caltrain.
• UP will transfer to Caltrain the rights for intercity passenger service north of CP Coast in Santa Clara, but not south of there.
• UP will agree not to pursue legal action against the electrification project.

This agreement could open a tiny sliver of hope for building grade separations that are both cheaper and more community-friendly without stubborn opposition from UP. On the other hand, it gives no hope for relief from freight PTC interoperability, justifying additional costs that have not already been sunk in the bottomless pit that is CBOSS.

News Roundup, March 2015

Regulations for 25 kV electrification.  After two years in the making, CPUC proceeding R1303009 appears to have produced the new rule book for stringing up high-voltage rail electrification in California, although the final document is still to be formally adopted by the Public Utilities Commission.  The final draft hammered out after numerous meetings by the high-speed rail consultants, freight railroads, utility companies and other interested parties thankfully bears little resemblance to the original draft proposed by the high-speed rail consultant, which was a mess.  While the new rules apply only to dedicated high-speed rail corridors without grade crossings or freight trains, the language is flexible and there appears to be room allowed for parties such as Caltrain and UPRR to agree on those particular items on a case-by-case basis, without resorting to an entire new CPUC rulemaking process for the peninsula rail corridor.  Most importantly, the new rules provide a clear framework that allows detailed engineering design of Caltrain's electrification project to proceed with a very low risk of future regulatory surprises.

Grade separations.   An unfortunate series of accidents and suicides have re-ignited the debate over grade separations in PAMPA (Palo Alto - Menlo Park - Atherton).  This portion of the corridor abuts some of the most expensive real estate on the peninsula and is home to the most contentious and litigious environment for local decision-making (or lack thereof, as the case may be), and it is gradually dawning on these communities that Something Must Be Done.  Grade separation is often misunderstood as an all-or-nothing proposition, when in reality it is a process that has been underway for decades.  The peninsula rail corridor is already 62% grade-separated today.  Communities up and down the peninsula are starting to talk more about finishing the remaining 38% of the job.

Quiet zones. Palo Alto recently conducted a study session on quiet zones, which would stop routine horn-blowing at grade crossings.  Curiously, the systematic use of train horns before every protected grade crossing is an American practice not usually seen in other countries, where crossing gates combined with visual and audible warnings are considered to provide a sufficient level of public safety.  But then again, those other countries don't have lawyers like ours.  The staff report contains a nice overview of the process for establishing a quiet zone; the main impediment seems to be the local community's assumption of legal liability for grade crossing collisions.

Peninsula HSR reboot.  After spending $45 million on environmental clearance and design of the original and much-reviled four-tracks-all-the-way peninsula HSR project, the California High-Speed Rail Authority shelved the plans with nothing delivered.  The Authority recently submitted a Project Update Report to the legislature, stating that a new environmental clearance for the peninsula segment is scheduled for completion in 2017, with construction complete in 2028.  [UDPATE 3/21]  Furthermore, an obscure Ridership Technical Advisory Panel Review of the California High-Speed Rail Ridership and Revenue Forecasting Process dated December 2014 includes the map graphic at right, and states that the Authority "has requested a stand-alone analysis of two individual segments of the overall system, to assess the viability of each segment operating independently for a handful of years prior to the completion of the system. (...) The Bay Area segment would require improvements to existing rail infrastructure. HSR service would be blended with existing Caltrain commuter rail."  The peninsula schedule may be pulling to the left.  To clear an EIR that fast, for a project so much more controversial than mere electrification, the process would have to be re-started very soon.  This may or may not be related to the choice of...

New Caltrain CEO.  Jim Hartnett was selected as Caltrain's new chief.  He is a consummate local political insider with no background as a transportation agency executive, other than chairing the Caltrain board of directors and vice-chairing the board of the CHSRA.  While he will no doubt be well equipped to navigate the choppy waters of inter- and extra-agency politics, he is less likely to shake up the Caltrain organization or to bring fresh outside-the-box thinking to the development of the "blended system."  While Caltrain has plenty of political and organizational problems to work on, the technical aspects of blending will determine the success of the rail corridor for decades to come.  Will Hartnett do anything about the top ten problems facing Caltrain, or will he just hold the current course?

High Voltage Rulemaking Update

Caltrain mascot?
(photo by wwarby)

UPDATE 05 November 2014: HSR lawyers hang Caltrain out to dry by amending the scope of the rulemaking process explicitly to apply only to "25 kV electrification systems constructed in the State of California serving a high-speed rail passenger system capable of operating at speeds of 150 mph or higher, located in dedicated rights-of-way with no public highway-rail at-grade crossings and in which freight operations do not occur."  Could Caltrain possibly not have seen this coming?

ORIGINAL POST, 25 May 2014: Feathers are really starting to fly in the Public Utilities Commission proceeding to establish a regulatory framework for 25 kV railroad electrification in California, under CPUC docket number R1303009.  Electric utilities and freight railroads are putting up a big fight against the California High-Speed Rail Authority that threatens to leave Caltrain hanging out to dry.

With the impending electrification of the peninsula corridor clearly in mind, the freight railroads asserted in January comments that "it remains unclear if the proposed rules will be sufficient for high-speed train operation in shared rights-of-way” and that “[i]f the CHSRA does not amend its petition to clearly state the intended scope of the rulemaking, the Commission should order further workshops to ensure that the proposed rules are carefully vetted out for application in shared rights-of-way."

Freight railroads are concerned about a number of compatibility issues, including electromagnetic interference with their signaling systems and vertical clearance for their freight cars.  Electrification could impair vertical clearances especially under bridges.

The CHSRA's response, filed in late March, was crystal clear:

The purpose of these rules is to establish uniform safety requirements governing the design, construction, operation and maintenance of 25 kV ac (alternating current) Railroad Electrification Overhead Contact Systems (OCS) constructed in the State of California in right-of-ways dedicated solely to passenger use with no public highway-rail grade crossings and in which freight operations do not occur.

(...)

[The freight railroads] know that the proposed General Order is not ambiguous and that it will not apply to track where freight operations occur. Their continuing refusal to be satisfied on this point reveals a desire to delay and obstruct this proceeding.

The peninsula corridor, of course, meets none of these criteria.  It is not dedicated solely to passenger use.  It has numerous highway-rail grade crossings.  Freight operations occur daily.  The freight railroads are understandably worried about this issue of scope, given that the legislature has allocated more than a half-billion dollars of HSR funding to electrifying the peninsula corridor; Caltrain plans to complete the electrification project in just five years.

Where does that leave Caltrain?

1. No regulatory framework exists for Caltrain's electrification project
2. CHSRA is explicitly not planning to establish such a framework
3. The freight railroads are vigorously opposed to the idea
4. Time is running out

That leaves Caltrain with few options.

The Short Line Option

It has been suggested that the rulemaking process would be less contentious if a smaller "short-line" freight operator were to buy the trackage rights UPRR enjoys on the peninsula corridor.  Presumably, such a short-line operator would be less adversarial in the negotiation of a mutually agreeable regulatory framework and technical solution for electrification.

This scenario unfortunately fails to take into consideration the precedent-setting nature of placing 25 kV electrification over any track where freight operations occur, regardless of ownership.  The big freight railroads, UPRR and BNSF, will be no less interested in such a proceeding at the CPUC than if their own tracks were being electrified.

The Nuclear Option

Section 8.3.c of the trackage rights agreement with UPRR specifically allows for the wholesale abandonment of freight service on the peninsula, should Caltrain "demonstrate a reasonably certain need to commence construction on all or substantially all of the length of the Joint Facilities of a transportation system that is a significant change in the method of delivery of Commuter Service which would be incompatible with Freight Service."  While 25 kV electrification over freight trains doesn't seem to be such a big deal on the East Coast or the rest of the world, the freight railroads' arguments in the latest CPUC proceedings could be construed as a belief that 25 kV electrification is fundamentally incompatible with freight operations in California.  Do we really want to go there?

Whatever option is pursued, there is little doubt that the freight railroads will have a big hand in the outcome, and that lawyers and judges will be involved.  The freight railroads have clearly demonstrated that they have:

• Intimate familiarity with the intricacies of the CPUC rulemaking process
• Ready access to a deep bench of experts who can testify on any technical subject
• An army of well-paid lawyers

Caltrain will bring a knife to a gunfight if they don't get their act together soon.

HSR Peer Review Group on Blending

The California High-Speed Rail Peer Review Group was established by AB 3034 (the Proposition 1A bond law) to independently review the HSR Authority's plans, assumptions, analyses and estimates.  The Peer Review Group recently sent the legislature its comments on the Draft 2014 Business Plan, including a number of recommendations concerning the plan to "blend" HSR and Caltrain on the peninsula corridor.  The Peer Review Group comments on blending follow:

Blended System issues. Access to San Francisco’s Transbay Terminal has posed a challenge to the program from the beginning. The ideal engineering outcome – a new, four track system separating HSR from Caltrain and freight service – was problematic because of its high cost and environmental impact. An alternative approach was adopted that blends the services of Caltrain and HSR on the same two track system, mostly within the existing right-of-way but with specific additions of passing tracks where needed and with the possibility of incremental increases in capacity when justified by demand. When combined with electrification of the Caltrain lines, paid half-and-half by Caltrain and HSRA, this approach should work to serve the needs of both systems at least through the first decades of the Phase I Blended system. In a number of our previous letters, the Group has supported the blended system approach; our comments below are aimed at improving its implementation.

The blended approach will require a true joint effort by Caltrain and HSRA with full participation of other parties including the Transbay Joint Powers Authority (that has the responsibility for the connection from the current Caltrain terminus at 4th and King Streets to the Transbay Terminal) and the Union Pacific Railroad (that has freight operating rights on the same lines). There are a number of issues on which the interests of the parties must be explicitly balanced if the blending is to work:

• Currently, Caltrain uses a platform height of 8” above rail. This means that boarding/de-boarding requires stepping up/down from the floor of the train (25” above rail), which can impose delays and risks of tripping and falling, especially when the needs of disabled passengers must be accommodated. The result is longer and less reliable schedules. The low platform height is dictated by the regulations of the California Public Utilities Commission (PUC) that require platforms to be no higher than 8” on tracks that may also carry freight trains. Unless a waiver from this regulation is granted, or expensive track work is installed, Caltrain will be limited to low platforms. At its current frequency of services, the lack of level boarding is manageable (if undesirable), but it will become much less tenable when Caltrain frequencies are increased and HSR trains are added.
   
• Under current plans, the floor of HSR trains will be about 50” above the rails, which is typical practice for most of the world’s HSR systems and consistent with Amtrak’s plans in the Northeast Corridor. Caltrain is experiencing rapid demand growth, a process that will accelerate when service to the Transbay Terminal is inaugurated. Caltrain’s plans call for acquiring new bi-level, electric multiple-unit rolling stock. Since the existing Caltrain coaches have a 25” floor level, consistency would suggest a 25” floor level for the new equipment. This would mean that platforms for the two systems would be at different levels, making transfers within station more difficult to arrange. This might be manageable at many common stations where Caltrain and HSR could have separate platforms, but the platform disparity would be more serious at the Transbay Terminal because the number of platforms is limited. As a result, routing of traffic into and out of the station will be more complex, and dispatchers will not have the flexibility to send either system to all platforms when delays or operating problems would otherwise dictate. One approach, turning a number of Caltrain services at 4th and King and limiting the number of Caltrain services to the Transbay Terminal, has been suggested, but would pose restrictions for Caltrain’s access to the Transbay Terminal.
   
• The basic standards of the PUC for electric catenary wire call for a clearance of 22 feet 6 inches above the rail. One the one hand, both Caltrain and HSR may want a lower catenary height in order to reduce construction cost for which the PUC will have to grant permission: on the other hand, the Union Pacific and port interests may want to protect the hypothetical possibility of future freight cars requiring even more clearance. HSR’s current electrification designs are appropriate for HSR-only operations and may not be acceptable for use in the Caltrain area. There are a number of specific locations where Caltrains’s clearance is already below 22 feet 6 inches, but there is no generally agreed height limitation.
   
• Positive Train Control (PTC) is a requirement of Federal law. Facing this mandate, Caltrain developed its own system – CBOSS – that is now being implemented. CBOSS may not be appropriate for use by HSR trains. If so, HSR trains may have to deal with two signal systems. In addition, the Union Pacific Railroad will have to operate in the same territory so will have to have conforming signal systems in its locomotives. 

None of these problems is impossible to resolve, albeit at added investment and operating cost by one or more of the parties. There is nothing unique about having multiple freight and passenger operators on a single line and there is experience in the U.S. and Europe with resolving the normal issues. All parties in the blended area are aware of the issues and there has been full cooperation among them.

We are concerned, however, that near-term decisions could be made by the parties acting separately that would ultimately compromise the performance of the system. For example, a decision by Caltrain not to plan for at least 25” platforms, which would provide an essential approach to level boarding, would lead to increased delays and uncertainty that could become unmanageable when Caltrain frequencies increase to meet the rapidly growing demand, especially that caused by the opening of the Transbay Terminal. This problem would get worse when four HSR trains per hour are added to the blended system in 2026. Caltrain will definitely need an expanded fleet, and bi-level cars are an efficient way to meet the need. That said, a decision to buy 25” floor level, bi-level coaches would mean that Caltrain and HSR would be committed to operating on incompatible platforms, which would add rigidity to a system that will be challenged for capacity. This problem could be alleviated if Caltrain ordered coaches that can serve both platform levels or if it adopted a uniform 50” platform, but either solution would clearly add investment costs above those planned. In all cases, the design of the electrification for Caltrain will need PUC approval and will need to consider the interests of all of the operators on the line.

This is a complex issue involving technology, investment, system performance and sequencing including the interests of a number of parties. Clearly there is no perfect answer and it is actually a problem resulting from success in attracting more passengers. We recommend that the Legislature request periodic joint reports from Caltrain, HSR and the Union Pacific Railroad that will use the tools available, including line capacity simulators, to assess the impact of alternative approaches to coach floor and platform height on capital and operating cost, capacity and reliability of both systems. This would include the impact on Caltrain if it has to construct 25” or 50” platforms. This study should also include the investment and operating cost impact of the alternative approaches to catenary height and platform clearance and should outline the decisions that the PUC will be asked to make.

Blended operations also pose the issue of accidents at grade crossings. Even at its existing speeds and frequencies, Caltrain experiences about 20 grade crossing and intruder deaths per year and generates delays on the local streets as autos and trucks wait for passing trains. This will get worse as train frequency and road traffic both increase over time. It would be difficult to overstate the risks of more frequent, faster and quieter Caltrain service combined with 110 mph HSR trains interacting with growing road traffic in the middle of California’s increasingly busy cities. We recommend that the Legislature ask Caltrain, HSR and the communities involved to develop a joint report assessing the likely future risks of increasing train traffic and speeds on the grade crossings in the areas impacted and identifying possible approaches to resolving the issue over time.

The Peer Review Group's comments are a wake-up call to start breaking out of the silo mentality that is prevalent in our transportation agencies, where "staying the course" is too often the overriding consideration.  The blend can only succeed if all stakeholders adjust their plans and projects to achieve better coordination and system-level integration.  The Peer Review Group understands that we are at a juncture where this opportunity must not be squandered.

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.

Grade Separation: The Decadal View

For the last few years of debate around the issue of high-speed rail, grade separating the peninsula rail corridor was often cast as an all-or-nothing proposition.  This extremist view clouded two important facts: first, the corridor is already mostly grade-separated (in 2013, only 40 road crossings out of 104 between San Francisco and San Jose will remain at grade); and second, grade separation is a slow and inexorable process that takes place over many decades.

If we assume the next several decades will be like the last several decades, we can take an educated guess about how and in what order grade separations will be built.  The criteria for prioritizing each project could be:

• creating long, uninterrupted stretches of grade separated right of way to enable higher train speeds without compromising safety
• creating a four-track mid-line overtake facility to increase the capacity of the corridor, to support initial HSR service
• separating crossings that rank highest in the CPUC's Section 190 Grade Separation Priority List
• delaying the most expensive and politically costly projects until last

Phase I is simply the completion of the San Bruno grade separation in 2013.  The San Mateo / San Bruno grade crossing being replaced was once rated #7 statewide on the CPUC's priority list.

Phase I: San Bruno Grade Separation

Phase II consists of four projects in San Mateo County, opening up two long stretches free of crossings by the early 2020s, including 14.8 miles free of crossings north of Burlingame, and 6.5 miles south of San Mateo.  This enables the future construction of the "short" mid-line overtake envisioned in Caltrain's corridor capacity analysis, and leaves only a few dense clusters of crossings within San Mateo County.  The new grade separations, in order of priority, are:

1. 25th Ave in San Mateo, the only grade crossing that remains between San Mateo and Redwood City.  Along with new grade separations already planned at 28th and 31st, this project enables the future 4-track mid-line overtake.
2. Broadway in Burlingame, an extremely congested crossing that has been slated for grade separation since the 1970s.  It rates #11 statewide on the latest CPUC priority list.
3. Linden Ave in South San Francisco, originally planned as part of the San Bruno project, but dropped from the final design in 2007.  Grade-separation at Linden is accompanied by the closure of Scott St, which becomes a pedestrian tunnel.
4. Center Street in Millbrae, a grade separation that will require a U-shaped elevated ramp due to the nearby BART subway tunnel box.  Such are the consequences of bad planning.

Each of these projects is independent and can be negotiated on a case-by-case basis with the four affected cities.  Starting in San Mateo County allows at least another decade for the Pacheco vs. Altamont debate to run its due course, legally and politically; these four projects are useful either way.

Phase II: San Mateo County Grade Separations

Phase III occurs mostly in Santa Clara County, creating a new stretch free of grade crossings from the southern half of Palo Alto all the way to San Jose in the late 2020s, assuming the routing of HSR over Pacheco survives as currently planned.  The last two grade crossings in San Francisco are also eliminated as part of the downtown extension project.  This phase includes the following six discrete projects:

1. Mary Ave in Sunnyvale, the corridor's busiest grade crossing in this county, with more than 25,000 daily vehicles
2. Sunnyvale Ave
3. Rengstorff in Mountain View, with about 18,000 daily vehicles
4. Castro in Mountain View, with about 9,000 daily vehicles
5. Charleston and East Meadow in Palo Alto, with a combined ~30,000 daily vehicles plus numerous pedestrians and bicyclists
6. 16th and Common in San Francisco, as part of the DTX project

Together, these six projects create a new 16-mile stretch of track that is entirely free of grade crossings.  The corridor is now left with just three dense clusters of grade crossings, in San Mateo / Burlingame, Redwood City, and PAMPA (Palo Alto - Menlo Park - Atherton), highlighted in orange in the figure below.  Note that these three dense clusters contain 27 crossings, and that to get this far, only 12 existing crossings were newly separated.

Phase III: Santa Clara County Grade Separations

Phase IV is the Great Redwood City Grade Separation.  This project, potentially for the early 2030s, would prolong the four-track mid-line overtake by three miles, by removing six grade crossings in downtown Redwood City.  Removing this cluster first makes sense from the standpoint of increased corridor capacity, the lowest number of new structures, the short mileage, and the entire project being politically simplified by virtue of its containment within Redwood City limits.

Phase V is the Great San Mateo / Burlingame Grade Separation.   This is a tougher project because it involves some of the most highly constricted portions of the corridor.  It also involves political and technical coordination between two neighboring cities, adding an additional challenge.  The sheer quantity of crossings (13 grade crossings + 4 obsolete grade separations within 2.4 miles) is also a complicating factor.

Phase VI is the Great PAMPA Grade Separation.  This project is left for last because it lies in the most expensive real estate on the corridor, involves coordination between three different cities, and is liable to cause the fiercest political and legal backlash anywhere on the peninsula.  Delaying it until last, perhaps into the late 2030s, allows the customarily long planning process to run its course without undue haste in all three affected communities.

We didn't arrive at today's state of grade separation (more than half) overnight.  It resulted from a slow and steady process that began in earnest in the 1940s.  The future is likely to be similar, and the peninsula rail corridor can reach a far improved state by separating just 12 more crossings over the next couple of decades, as described in Phases II and III.  This dozen should be prioritized for construction, before any of the crossings in the remaining dense clusters are touched.

The Great Platform Height Transition

The editorial position of this blog has always been that Caltrain and high-speed rail ought to be 100% interoperable, to derive the maximum transportation benefit from the considerable investment about to be made in the peninsula corridor. This creed can be summed up in a simple slogan: Any train, any track, any platform.

As was previously pointed out in the discussion of platform heights, it is most likely that high-speed rail will make use of high platforms. "Any train, any track, any platform" would require Caltrain to convert its own platforms to the same height as HSR. It's one thing to gripe about platform heights, but quite another to pull off the transition without interrupting commuter service. How can it possibly be done?

Here's an idea: (click to enlarge)

The end result would be a desirable center island platform for Caltrain. One could even build it such that the edge could be cut back to a gentle curvature after construction, resulting in the compact "football island" configuration when HSR is added.

Another useful feature of this concept is that it lends itself to phased construction of the four-track stretches where they are most needed. Commuter trains could use the extra track capacity years before HSR enters service, achieving a level of "independent utility" that the framers of AB 3034 might be proud of.

General Order 26-D

ADA regulations mandate level boarding for Caltrain's new electric trains. Since it is impractical to build a rail car with a floor just 8 inches above the rails, at the same height as the existing platforms, this mandate will require all platforms to be raised from their current height of 8 inches regardless of their final height, whether it be the same as HSR or something in between.

Platform edges higher than 8 inches are prohibited under the California Public Utilities Commission's General Order 26-D, which requires an ample clearance envelope to allow the outdated practice of "train men" riding on the side of freight trains.

There are only two ways around 26-D: compliance by way of a complex, failure-prone and maintenance-intensive technical solution that will saddle Caltrain with endless operating and maintenance costs in order to accommodate two freight trains per day, or... a waiver. Caltrain has now demonstrated its ability to navigate bureaucracies and obtain regulatory waivers; why not obtain permission to move one sign (pictured at right) south from San Francisco to Santa Clara?

Platform Height

Among the things on your mind as you step across the platform gap to board a train, the height of the platform above the rails probably ranks last. As it turns out, this dimension--and correspondingly, the floor height of the train--is very important. It determines:

• platform dwell times, or how long it takes passengers to get on and off;
• interoperability between two train systems, Caltrain and HSR;
  
• accessibility for the disabled and people carrying bulky items (luggage, strollers, bicycles);
• the available options for procuring affordable, off-the-shelf train designs.

Level Boarding

The Americans with Disabilities Act (ADA) mandates that all new rail vehicles and platforms provide level boarding, with the height of the train floor within 5/8" (16 mm) of the height of the platform, a tight specification that is quite difficult to achieve in everyday practice. The grand staircase that greets most Caltrain passengers will no longer be allowed because the ADA requires "the most integrated setting reasonably achievable." Caltrain got by until now by using a hodge-podge of grandfather clauses and band-aid solutions allowed under ADA law, but as the system transforms from an old-style diesel commuter railroad to a modern, fast and frequent transit system, level boarding and full accessibility is no longer a negotiable feature. Indeed, level boarding features prominently among the goals of Project 2025, Caltrain's blueprint for reinventing the peninsula commute.

That does leave the question unanswered: exactly which height is appropriate for this level boarding to take place? As we will see, this question has far-reaching implications for the peninsula corridor.

Caltrain's Plan

Caltrain has for many years harbored the desire, if not the financial means, to operate swift electric multiple unit (EMU) trains. These trains would increase service speed and frequency, especially at those stations that saw service cut back to make room for Baby Bullet service.

Going back many years, Caltrain's studies invariably conclude that such EMUs should necessarily have two levels (an upstairs and a downstairs), much like Caltrain's existing fleet. The reasons have to do with providing a certain passenger capacity under a cost trade-off between service frequency and train capacity, fitting within platform and train length limitations, taking full advantage of the ample vertical clearances that are available... and last but not least, perhaps also the sheer Strength Of An Idea.

Caltrain wishes to procure its new trains on the global marketplace. A sampling of various European bi-level EMUs under consideration, with corresponding entry floor heights:

• France - Alstom Coradia Duplex: 600 - 645 mm (24 - 25")
  
• Germany - Siemens Desiro: 600 mm (24")
  
• Switzerland - Stadler Dosto: 570 mm (22")
  

For reasons related to vehicle packaging (fitting all the train's innards, systems and amenities around the passenger space), as well as historical European platform standards, these double-deck EMUs typically have entry doors and vestibules on the lower deck, with a floor height of 570 - 645 mm (22" to 25"). High-platform EMU designs are less common, although they do exist in Paris and Sydney.

Enter HSR

While HSR on the peninsula corridor has long been a dream, the increasing tempo of events (Proposition 1A, the federal stimulus, environmental planning for the San Francisco - San Jose HST project) has made it increasingly likely that Caltrain commuter trains will mingle on the peninsula corridor with a steady flow of long-distance high speed trains linking the region to the rest of California. Caltrain and the California High Speed Rail Authority (CHSRA) have signed a memorandum of understanding establishing a broad framework for sharing the peninsula corridor, which envisions "mixed traffic from Caltrain commuter rail and the high speed train service capable of operation on all tracks."

The MOU identifies the urgent need for a systems engineering integration plan, a detailed technical framework for how Caltrain and HSR will mesh together. Importantly, this plan will have to address the issue of level boarding, and whether "mixed traffic" also applies to platform tracks.

The global HSR marketplace, from which the CHSRA will procure its trains, clearly tends toward so-called "high floors" about four feet above the rails: the floor of the rail car's entry vestibule is built high enough to fit the train's wheels underneath. A sampling of various HSR makes and models, with entry floor heights:

• France - Alstom AGV: 1155 mm (45")
• Germany - Siemens Velaro: 1210 mm (48")
• Japan - Kawasaki / Nippon Sharyo / Hitachi 700 Series Shinkansen: 1250 mm (49")
• Spain - Talgo 350: 755 mm (30")

HSR will quite naturally gravitate towards high platforms.

Regulatory Considerations

Platform heights in California are governed by the federal Department of Transportation and the California Public Utilities Commission. There are many laws on the books, and yet more undergoing approval. Taken together, they form a complicated regulatory thicket that has previously, and probably will again, produce odd solutions. The key regulations that govern platform height include the following:

• Platforms must be within 5/8" of the height of the train floor (36CFR1192.175 and 36CFR1192.93) for level boarding
  
• HSR trains must use high-platform level boarding (36CFR1192.175), typically understood as about four feet floor height
  
• Commuter platforms must provide full-length level boarding (DOT guidance)
• There may not be steps down into a train (DOT guidance)
• Commuter platforms may not exceed 8" above top-of-rail (CPUC General Order 26) to provide clearance for freight trains.
  
• New commuter cars must have a 15" floor height for compatibility with Amtrak (see proposed change to 49CFR37.85, effectively already law)
  

Now it gets really confusing.

These regulations not only contradict each other, but also lead to the strange notion that HSR and commuter rail are inherently incompatible and must therefore be built to differing platform heights. Regardless of this legal mish-mash, it is unlikely that the CHSRA will choose a platform height with Caltrain compatibility in mind; they will choose whatever suits the high speed rail system. That leaves Caltrain to follow their example... or not.

One can easily see where this is all headed, based on the figure at left: with bi-level EMUs, Caltrain is likely to end up with an entry floor height in the low twenty inches, while HSR will end up in the forties. The non-negotiable requirement for level boarding would result in two different and incompatible platform heights. Does that even make sense?

The Consequences of Platform Incompatibility

If one considers the peninsula corridor as a transportation system rather than two independent services simply sharing a right of way, platform compatibility emerges as a key enabler for realizing the potential synergy between HSR and Caltrain, with one serving as a feeder for the other. HSR can operate as a Flight-Level Zero airline with enormous parking garages and rental car facilities, or it can be deeply integrated into an efficient network of transportation where riding the train to your destination anywhere on the peninsula corridor is not only possible, but convenient and desirable.

One of the greatest opportunities currently facing rail planners is the provision of cross-platform transfers between Caltrain local and express trains. Under this operational concept, a local and an express show up simultaneously, on opposite sides of the same platform, and exchange passengers. In effect, the express overtakes the slower local at the platform, rather than somewhere between stations, allowing passengers to switch conveniently from one to the other. Such exchanges, operating on regular clock face schedules, would enable fast and frequent service to and from all the stations currently under-served by Caltrain, such as Belmont, Burlingame or San Antonio, and would greatly magnify the utility and efficiency of Caltrain as a feeder to peninsula HSR stops. Caltrain to Caltrain cross-platform transfers, the key to this highly desirable operational concept, inherently require the same boarding height on both sides of the platform as shown in the figure at right.

Proceeding with two incompatible platform heights would have the following negative impacts:

• A cross-platform coordinated transfer between local and express commuter trains would be precluded at peninsula HSR stops, unless additional platforms were built. As shown in the figure under Option B, the two key transfer points on the peninsula corridor (Millbrae and Palo Alto / Redwood City) would preclude cross-platform transfers precisely where they are most needed, permanently crippling Caltrain's development potential.
  
  
• If cross-platform Caltrain transfers were nevertheless implemented at the Millbrae and Palo Alto HSR stops, these large stations would have to be further expanded with additional platforms (shown in the figure under Option C) and up to six tracks (if HSR infrastructure were completely secured). Such enormous stations, approaching the size of an aircraft carrier, would be out of scale with the surrounding community.
  
  
• San Francisco's Transbay Transit Center would be operated as two independent mini-terminals, with four HSR platform tracks and two Caltrain platform tracks. The loss of redundancy from the inability to assign any train to any platform would (a) exacerbate traffic jams in the station approach (by limiting the available paths and thus curtailing terminal capacity); (b) allow small incidents that delay a train (e.g. a medical emergency or law enforcement activity) to propagate to other trains; and (c) prevent spare capacity (unused platform tracks) from being re-allocated between Caltrain and HSR in response to actual travel demand, as opposed to ridership projections made decades into the future.
  
  
• The resulting inability of the Transbay Transit Center to support a full Caltrain rush-hour schedule would require the existing station at 4th & King streets to be retained indefinitely, thus confusing commuters, contradicting San Francisco's 1999 Proposition H, and occupying many acres of land that would be more usefully developed for other purposes.
  
  
• The San Jose train station, already planned as a massive double-deck structure, would require dedicated tracks and platforms for each service. With compatible platforms, it is likely that a single-deck configuration could meet the various needs of Caltrain, HSR, ACE and Amtrak.
  
  
• Under delayed or otherwise unusual traffic conditions, high speed trains could not stop at a Caltrain platform to discharge passengers.
  

The Transition Conundrum

If a common, compatible platform height specification for both Caltrain and HSR is the desired outcome, how do we get from here to there? One of the key requirements for the development of the peninsula rail corridor is to do so without interrupting Caltrain service, to avoid dumping another 20,000 cars on congested roads. Furthermore, changing the height of station platforms, or procuring and commissioning new trains, are not done at the flip of a switch: each would last many months. Under those conditions, converting Caltrain to a different boarding height will be tantamount to changing the wing of an airplane... while in flight. That's not to say it is impossible, but it will require some very creative solutions from Caltrain, an issue that we will revisit later.

In the meantime, now would be a fine time for Caltrain to initiate the waiver process for GO-26D, since it is sure to encounter stiff opposition and delay from certain entrenched interests.

Regulatory Vacuum

Preliminary design for the California High Speed Rail project is proceeding in the absence of key regulations from the California Public Utilities Commission (CPUC), the Federal Transit Administration (FTA), the Federal Railroad Administration (FRA), and numerous other agencies. While high speed rail is a very mature technology, it is still foreign and exotic in the United States, and our regulatory agencies do not yet have an effective or complete regulatory framework in place to direct the development of high speed track and trains. The regulatory vacuum is already causing some strange and potentially regrettable design decisions to be made, with negative consequences for the peninsula corridor.

Platform Heights

The side clearance dimensions around passenger rail platforms in California are regulated by the CPUC under General Order No. 26, originally issued in 1948, covering every relevant railroad situation from stock chutes to icing refrigerator cars. Where freight trains share tracks with passenger trains, as they do on the peninsula corridor, G.O. 26 limits passenger platforms to a height no more than 8 inches (203 mm) above the top of the rails (ATOR) to allow trainmen to ride on the side of freight cars without fear of getting clipped. Of course, none of these olde-tyme railroad practices are very relevant to 21st century rail technology.

Nevertheless, 8 inches is the maximum height of all existing Caltrain platforms. Taller platforms are allowed, but only beyond 7 feet 6 inches (2.3 m) from the track center line; in other words, taller platforms are only allowed if they do not come closer than about 3 feet from the side of a train. A lot of good that does for passengers! Combine G.O. 26 with ADA accessibility requirements, and you get a ghastly regulatory abortion called a "mini high platform" (see figure at right), to facilitate wheel chair boarding using a so-called "bridge plate" manually placed across the yawning moat between the high platform and the train. Mini-high platforms continue to sprout up and down the Caltrain line, most recently in Redwood City and Menlo Park, while elsewhere in the world, humans have discovered level boarding.

Of course, the regulatory rigors of accommodating freight trains are not anywhere on the CHSRA's radar screen, which is why they are planning for level boarding platforms regardless of where Caltrain eventually ends up--one can only hope, higher than eight inches. At stations to be served by both HSR and Caltrain, namely San Francisco, Millbrae, Redwood City or Palo Alto, and San Jose, it is quite possible that we will end up with different, incompatible platform heights with station tracks forever assigned to one or the other type of train. This runs counter to the most basic principles of interoperation, where the flexibility to assign any train to any platform (in a pinch) is paramount.

Moving beyond MOUs, who will bring about amended regulations to ensure that we have a common platform standard for HSR and Caltrain?

Who will make sure this standard allows the off-the-shelf procurement of new trains, without costly redesign? A hint: the most relevant platform heights are 22 inches (550 mm) and 30 inches (760 mm).

Why is Caltrain apparently not vigorously pursuing a waiver of G.O. 26?

High Voltage Electrification

Like platform clearances, overhead electrification of railroads is regulated by the CPUC. General Order 95 specifies the rules governing overhead electric line construction in California. Garden-variety 25 kilovolt overhead electrified railways do not exist in California, and G.O. 95 therefore does not allow them. That's right: 25 kV electrification is currently illegal in California. Caltrain has long-standing plans to electrify the peninsula corridor, and had been pursuing new regulations with the CPUC to cover 25 kV trains. More recently, the approach appears to have shifted towards obtaining a waiver from G.O. 95 instead.

Whatever happens, why is the heavy lifting for high speed rail being left to Caltrain? Moving beyond MOUs, where is the coordinated approach with HSR?

Safety and Train Control

Railroad safety in the United States is regulated by the FRA in a manner that places a premium on crash survival over crash avoidance. That's why we still have the 19th-century practice of train engineers calling signal aspects to their conductor (unless texting on their cell phone), with few if any automated systems to catch human errors. This safety philosophy is well-suited to the cost structure of the heavy freight rail business that dominates our landscape. On the opposite end of the spectrum, high speed rail safety relies almost entirely on avoiding a crash in the first place--not unlike airliners. In Europe, high speed trains zoom through dense fog at nearly 200 mph, with a train control computer watching over the driver's every move. Both philosophies achieve the intended level of safety, but what is supposed to happen when you need to mix both types of traffic on the same corridor, as is planned on the peninsula?

To their great credit, Caltrain is taking the national lead on the issue of mixed traffic regulations, as part of their plan to operate European-style passenger trains that are considered "non-compliant" with existing FRA safety regulations. As of September 2008, Caltrain staff estimated the likelihood of obtaining regulatory relief to be closing on 90 percent. That's very encouraging.

Caltrain's safety concept includes a radio-based positive train control system to be installed on the peninsula when the corridor is electrified, known internally as CBOSS (Communications-Based Overlay Signal System). This raises a host of questions, again moving beyond generic MOUs:

Why is Caltrain specifying CBOSS as a wireless system, excluding an entire segment of the wired train control market?

Is CBOSS an expensive re-invention of the wheel, where existing train control systems such as the Japanese Digital ATC and the European ETCS Level II might plug-and-play?

Why is Caltrain moving ahead with a solicitation this year, fueled by $500k in federal funds earmarked by congresswomen Jackie Speier and Anna Eshoo, for implementation in the next couple of years--before HSR train control requirements are fully defined?

Why should Caltrain be taking the lead on this critical technology issue, when the standard they develop will need to be applied California-wide to the entire HSR system and likely other HSR corridor traffic such as Metrolink, Union Pacific and BNSF?

Doing It Right

Sometimes, doing it right means stopping and charting a new course. One of the fundamental principles of good systems engineering is that you must develop a complete and concise set of design requirements before you dive into the detailed design of station platforms, overhead electrification or complex train control systems. Caltrain does not seem to have fully absorbed the extent to which HSR alters the requirements of nearly every improvement project in their pipeline. Preliminary design activity on all the above items should be slowed and resources re-allocated towards bringing the technical requirements and regulatory framework into better focus. The successful integration of HSR and Caltrain on the peninsula corridor depends on it!