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.

Emergency Exit Fail

Caltrain's new EMU train cars have an unusual configuration with two sets of doors. The lower level doors will be used at existing Caltrain stations, while the intermediate level doors (above the wheels at the ends of each car) are intended to be used at an undetermined date in the 2030s once these trains begin sharing stations with California high-speed rail, which will use high-floor trains and high platforms with boarding at about 50" above the rail. The California High-Speed Rail Authority, which Caltrain cryptically refers to as "external stakeholders," required this design feature as a condition of funding Caltrain's modernization to the tune of $750M, to maintain the option of sharing platforms at future HSR stations in San Francisco, Millbrae and San Jose.

The Original Plan

To maximize the short-term seating capacity of the new trains until the 2030s, Caltrain specified that the intermediate level should have temporary flip-up seats installed in front of the unused doors, five per door vestibule, with the seating blocking off the doors like this:

Configuration of intermediate level in A, B, C, E, and G cars

Because EMU cars are filled with electrical cabinets (labeled with yellow lightning bolts), the seating capacity of the train is reduced compared to a conventional train. This is the price you pay for not having a locomotive; all the bits that make the train go still need to find a place, which makes for a challenging packaging problem in a bi-level train. The reduced seating capacity of the train has been controversial and makes these temporary seats quite important. For each 7-car train, there are 70 of these intermediate level flip-up seats that make up a non-trivial 10% of the overall seating capacity of 667.

At some undetermined future date when the intermediate doors would be needed for compatibility with high platforms, the blue flip-up seating modules would be removed from the intermediate level.

A Regulatory Conundrum

In the design of any new train, federal safety regulations require that any passenger seating compartment be fitted with at least two emergency exit windows (for passenger egress) and two rescue access windows (for first responder ingress). The intermediate level counts as a passenger compartment because these flip-up seats are located within it. However, the intermediate level does not have what regulations consider to be a window; the only opening to the outside is through the doors. This set up a conflict with safety regulations.

In late 2017, Caltrain petitioned the Federal Railroad Administration for a waiver (docket FRA-2018-0003) by arguing that the emergency release feature of the doors would provide an equivalent level of safety, despite not meeting the letter of the regulation, allowing emergency access by climbing over the seat backs.

In June 2018, the FRA denied Caltrain's request because the flip-up seating installed longitudinally such that it blocks the doors could impede egress and access and therefore did not meet the intent of the regulation. The FRA stated that "the absence of need for these intermediate level doors to support current revenue boarding and alighting requirements does not negate the necessity for an unobstructed path in the event of an emergency." Curiously, this unobstructed path requirement applies only to doors, not to windows!

Implicitly, Solution A is to remove all seating from the intermediate level of the affected cars, which effectively sidesteps the emergency window requirement. But given that seating in Caltrain's EMUs is already quite limited, this solution seems like a non-starter as it would reduce seating capacity of a 7-car train by 9% from 667 seats to just 617 seats.

Solution A: not a passenger seating compartment

The FRA helpfully suggested some other possibilities.

Solution B: equip the intermediate level doors with a regulation-size emergency window of minimum dimensions 26" wide by 24" high. Unfortunately, that is too large for the dual-leaf design of the train doors; in other words, the window in each door leaf is too narrow to function as an emergency window.

Solution B: the minimum clear opening is too big for dual-leaf doors

Solution C: replace the intermediate level doors with a plug panel (essentially, a structural wall panel that does not function as a door) fitted with a regulation-size emergency window of minimum dimensions 26" wide by 24" high, until such time as the door-blocking seating is removed, the panel is removed, and the doors and platform bridge plates are re-installed.

Solution C: doors replaced by plug panels

Caltrain is now in the process of pursuing Solution C, plug panels. This change order is expected to cost about $4 million total up front, about $30000 per car, or $7000 per door. When intermediate-level doors are required a decade or more from now, a net sum of approximately another $10 million ($14 million future installation cost to be set aside, minus $4 million of door maintenance savings) would be needed to retrofit them. That is a LOT of money for a change that fundamentally reduces and complicates compatibility with HSR stations and platforms.

Other Solutions

There are other solutions that strike a better balance of functionality and simplicity without a seven-figure cost impact.

Solution D: short of removing all the seating from the intermediate level vestibule, the regulations require only one emergency window (instead of two) if there are four or fewer seats in the compartment. Removing seats from one side only and applying for a new waiver to allow unobstructed use of one of the doors in lieu of a single emergency window could work, addressing the FRA's stated concern with door obstruction. This would reduce seating capacity of a 7-car train by just 22 seats or 3% (5 seats lost in cars A and B, and 4 seats lost in cars C, E and G).

Solution D: reduced seating with unobstructed emergency access

Solution E: reconfigure the mounting bracket for the flip-up seating so that seats flip up and out of the way of the doors when not used, allowing the unimpeded use of both doors in lieu of emergency windows. This solution requires applying for a new waiver to allow the use of doors in lieu of emergency windows, but also addresses the FRA's stated concern with door obstruction. Placing the flip up seats in this manner would reduce the clear width of the door opening by a couple of inches on each side, from 51" to about 47", with no reduction to seating capacity.

Solution E: change flip-up seating orientation to provide unobstructed door access
(flip-up seats are shown in use; they fold flush against wall when not occupied)

Solution E would require no modifications whatsoever when the intermediate level doors are needed in the future, and could be implemented at all doors throughout the train including the lower level, adding seating capacity. Seats placed in doorways may sound like a bad idea, but in a crowded train, social signaling fairly quickly communicates to occupants of these seats that it's time to stand up and make way. This is the French "strapontin" seating in common use on some of the busiest rail lines in Paris:

Flip-up seats in a doorway of a brand new Bombardier EMU on Paris RER line D.
(foreground at left) credit: Wikipedia / KiHa 52

Indeed, the photo above, taken inside the same Bombardier EMU often vaunted in front of the Caltrain board by a certain member of the public as having so much more seating than Stadler's EMU, shows one of the secrets of achieving very high seating densities: flip-up seating in all doorways. The other three secrets are five-abreast seating, not having as much space dedicated to bikes, and lower acceleration performance that requires fewer electrical cabinets, leaving more space for seats. After adjusting for these four factors, it turns out that the Bombardier EMU provides no higher seating density than the Stadler EMU.

Ultimately, it is entirely possible that Caltrain simply does not wish to interface with high-speed rail in any station as a matter of policy, because it would require sharing and collaborating with another agency, and solving a somewhat complicated ADA compliance problem. Which agency would voluntarily bring that upon itself? Caltrain already took the HSR money, and installing plugs will "erase" the clunky and unpalatable concession they made in the name of compatibility, with the further bonus of not requiring another run at the FRA for a new waiver. The complicated ADA compliance issues associated with interior lifts are kicked as far down the road as possible!

No matter how you look at it, Caltrain's chosen approach is a ~$15 million mistake that reduces and complicates compatibility with HSR stations and platforms. There are cheaper, simpler and easier ways to achieve compliance with emergency window regulations. It's not too late to change course.

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.

New SF Caltrain Terminus Opens at 0 tph

Zero trains per hour (tph) is the inaugural Caltrain service level at San Francisco's new Transit Center, which opened to the public today after a decade of construction. The grand opening of the center, with its expansive $400 million basement featuring ghost tracks, ghost platforms and a ghost passenger concourse will no doubt crystallize the increasingly urgent transportation need for the downtown extension (DTX) of the peninsula rail corridor. Only then will train service increase beyond the current level of zero tph.

Huge opening day crowds at the Transbay Transit Center. Photo by Adrian Brandt.

Why build DTX?

Simple. Within a half mile radius of the Transit Center, there are more jobs than within a half mile radius of every station along the peninsula rail corridor from San Francisco 4th and King all the way to Gilroy, COMBINED! Even before high speed rail shows up, this is a piece of infrastructure that makes perfect sense. Or does it?

An epic opportunity for transit funding extortion

The clear (and, as of today's opening, agonizingly present) need for the DTX sets up a deliciously fat and juicy prey for the transportation-industrial complex, which you can think of as a hungry snake. Here we are, in a strong economy, in one of the richest cities on Earth, facing a specific and obvious transportation need: they can name just about any price. The latest estimate for the biggest meal that the snake can swallow is six billion dollars, and that's only the start. Scope creep, dizzying amounts of contingency cushioning, and construction change orders are sure to drive it far higher. Civil engineering megafirms, labor unions, and complacent and poorly coordinated government agencies are salivating at the prospect of feasting on the DTX. The bigger it gets, the more sated and comfortable everyone will be, with the notable exception of the suckers who pay taxes and ride trains.

The DTX project needs a major cost cutting exercise

"It is difficult to get a man to understand something, when his salary depends on his not understanding it." This insight by Upton Sinclair applies to any attempt to reduce the scope or optimize the cost effectiveness of the DTX project. There isn't and probably won't be a true will to do it, but in a pretend world where the interests of taxpayers and riders came first, where might you start cutting scope?

1. Delete the Pennsylvania Avenue tunnel extension. There is a perfectly serviceable tunnel already available. Engineering acumen should be brought to bear to overcome the (otherwise delightfully profitable) constraints of building a new trenched grade separation by figuring out how to shore up I-280 during excavation; how to cross the SFPUC's giant new sewer; how to duck under 16th street using a steeper 2.5% grade than the train people would prefer; and how to build temporary "shoo-fly" tracks under I-280 during construction now that the area is hemmed in by fresh UCSF construction. The usual paint-by-numbers engineering that deploys freight train design standards as "constraints" shows this to be categorically impossible, but is it really? Sharpen your pencils.
    
2. Delete the mezzanine level at 4th and Townsend. Station mezzanines are a knee-jerk (and delightfully profitable) design feature of every recent piece of rail infrastructure in the United States. Wedged above the tracks, underneath, in the sky or in a cavern, mezzanines tend to sprout everywhere. In this case, a mezzanine makes passenger access more circuitous and pushes the track level much deeper, increasing the depth of excavation. The mezzanine and station become an enclosed underground space, triggering an avalanche of fire safety requirements that greatly increase cost and complexity, with all manner of vent structures and evacuation shafts. The right answer is simple, direct and free-flowing access from platform to street, and an open station ceiling that vents to the street through a slot built into a raised median on Townsend Street-- as wide as necessary to treat the structure as an open station under fire safety regulations.
    
3. Daylight as much of the shallow Townsend Street portion of the alignment as possible, with a central median vent slot (just like in Los Angeles on the Alameda Corridor, where three of the nation's busiest diesel freight tracks are concealed beneath the street with a vent slot as narrow as six feet). This configuration has the potential to simplify the engineering considerations and costs related to fire safety, and even improves rail operations: without the onerous fire safety requirement of having only one train at a time occupy each tunnel ventilation section, operation of the entire DTX becomes less constrained.
    
4. Slim down the three-track tunnel, another one of Sinclair's salary considerations, to two tracks instead of the planned three. The Rail Alignments and Benefits (RAB) operations analysis, carried out by a premier Swiss rail operations consultancy, concludes on page C-68 that "Under normal conditions, only two tracks are required in the tunnel leading up to the TTC to operate the analyzed service plans. More detailed analysis is recommended to identify the most effective approach to provide infrastructure redundancy (e.g. the proposed third tunnel track) to help mitigate the potential effects of major service disruptions." The clear implication here, artfully worded so as not to upset Sinclair's salary men, is that a third track is not necessarily the best or only approach to achieve infrastructure redundancy.
    
5. Add three 400-meter underground storage tracks, feeding in towards the Transit Center instead of the peninsula, along the northwest edge of the existing 4th and King station footprint. The fire safety requirements for this underground infrastructure would be less stringent because it would not be occupied by passengers. With beefy foundation columns bored down to bedrock to straddle this yard, the entire footprint of the site can still be redeveloped above grade, safeguarding San Francisco's desire to use "value capture" from this increasingly coveted parcel to finance DTX construction. The resulting train storage capacity is far more conveniently located than the remote yard sites currently proposed at Oakdale or Bayshore, reducing long-term operating costs. Even skyscrapers can be built on top of train storage: see Hudson Yards.
    
6. Rationalize the Transit Center approach tracks to speed up train movements. The throat of the station has been identified as a key bottleneck for train movements (see RAB operations analysis page C-96, "Key Findings of Conceptual Planning"--and recall that you read it here first). An optimal layout has been identified that better enables concurrent arrivals and departures of two trains (see page C-117 of same). Precious seconds saved in the station approach can increase the traffic capacity of the DTX and make it more resilient to disruptions.
    
7. Don't use exotic and expensive tunneling methods when their sole purpose is to keep businesses along the DTX route healthy during construction, by avoiding cheap but disruptive cut-and-cover methods. The intent is noble, and the recent impact of Central Subway construction in Chinatown is painful and fresh in our minds, but this sort of thing rarely pencils out for anyone but Sinclair's salary men.

Only after a draconian cost cutting exercise might it begin to make sense to build the DTX. At a price point of six billion dollars for a couple of miles of tunnel, we regretfully should keep service levels at zero trains per hour.

Core Capacity Math

With federal funding for Caltrain modernization on indefinite hold, a diverse flock of vultures have started circling the skies over the peninsula corridor--opponents of electrification, boosters of peninsula BART, opponents of high-speed rail, and detractors of rail or transit in general. Some opponents have latched on to a perceived vulnerability of the modernization project, using a legal parsing of federal regulations to allege that Caltrain's application for federal transit funding is fraudulent and illegal. This sensational claim merits closer examination.

FTA "Core Capacity"

The $647M of funding that Caltrain has pursued for several years, and came agonizingly close to obtaining, is allocated by the Federal Transit Administration and disbursed by congress under a competitive grant program known as a Capital Investment Grant or nicknamed "5309," after the section number of the United States Code under which the program is defined. One of the ways to obtain federal funding under this program is to increase the capacity of an existing transit system by at least ten percent. This is known as a "core capacity" grant, the type that Caltrain is pursuing.

The fracas is all about this ten percent, and whether Caltrain is actually meeting the criteria for eligibility.

To prevent gaming of the system, section 5309 policy guidance specifies how that ten percent increase is to be counted for a core capacity project to become eligible for funding. Importantly, the FTA makes an artificial distinction between "light rail / heavy rail" (where passengers traditionally sit and stand) and "commuter rail" (where passengers traditionally only sit) that fundamentally changes the metric used to measure capacity.

• Light rail / heavy rail capacity is measured by "peak hour person capacity in the peak direction," a measurement that includes standees and is based on floor space.
   
• Commuter rail capacity is measured by "peak hour peak direction seated load," a measurement that excludes standees and is based solely on seat count.

Under this uniquely American taxonomy, Caltrain is an odd duck: the modernization project seeks to transform it from a traditional diesel commuter train into a swift and frequent transit system whose attributes will bear a closer resemblance to a heavy rail system like BART than to a stereotypical American commuter train. Indeed, Caltrain's choice of a Swiss train design underscores the cultural disconnect with the rigid system of American train categories.

If you needed any more proof, BART is removing seats to increase capacity!

EMU seating capacity

As ordered, Caltrain's EMUs will have significantly fewer seats per train  than today's six-car diesels. EMUs are not a magical technology: they may lack a locomotive, but all the traction components that would normally be found in the locomotive still need to be accommodated elsewhere in the train. In a preliminary brochure of Caltrain's new EMUs, the traction bits show up as cabinets marked with a spark symbol. These things take up space, so a six-car EMU offers fewer seats than a traditional six-car train hauled by a diesel locomotive.

(In passing, some have blamed the lower seating capacity of the Stadler EMUs on the dual door configuration. A cursory review of proposed seating layouts can retire this fallacy.)

The seating capacity directly counted from the brochure was 573 seats per six-car EMU, although Caltrain's FTA grant application assumes only 558, averaging just 93 seats per car.

A Shifting Baseline

Ten percent, but compared to what? The baseline present-day capacity is also contentious, since Caltrain's record ridership has created the need to provide more seats today.

In Caltrain's September 2016 grant application materials and correspondence with the FTA (helpfully obtained under a Freedom of Information Act request by CARRD Morris Brown), the capacity baseline is tabulated as 3403 seats per peak hour per peak direction, with a net increase of 365 seats (barely squeaking by with a 10.7% increase) to a total of 3768 after the modernization project is completed.  Detailed tabulation is provided below, as extracted from the grant application.

Detail of Existing Operations					Commuter Rail
Train #	Train Line Reference (e.g. Name/Color/Number)	Departure Time	Number of Cars	Seats per Car	Seats Per Train
1	#217	6:57	5	121	605
2	#319	7:03	6	132	792
3	#221	7:18	5	120	600
4	#323	7:45	6	131	786
5	#225	7:50	5	124	620
Total	During the Peak Hour				3,403
Detail of Operations At Project Opening					Commuter Rail
Train #	Line Reference	Departure Time	Number of Cars	Seats per Car	Seats Per Train
1	#305	7:00	6	134	804
2	#113	7:07	6	93	558
3	#115	7:12	6	93	558
4	#307	7:29	6	122	732
5	#117	7:36	6	93	558
6	#119	7:42	6	93	558
Total	During the Peak Hour				3,768

Opponents have pointed out that well before the date of the FTA grant application, train 225 was converted to a six-car Bombardier consist seating about 790 passengers, as was train 217, thus increasing today's peak hour baseline by 170 + 185 = 355 seats, and cutting the future capacity increase fully in half from 10.7% to an ineligible zero percent 5%. Caltrain may have done itself in simply by serving its customers today.

How to solve the FTA seating equation
To meet the FTA requirements without question, and to shoo those vultures away, here are some solutions Caltrain could reasonably pursue:

• Build the train cars 3.2 meters wide with five-abreast seating on the upper deck (the lower deck would remain four-abreast with a wider aisle). A car width of 3.2 meters is within the AAR Plate F loading gauge that is cleared to operate on the peninsula corridor, and is a common width in East Coast commuter railroads (the LIRR M7, the Metro North M8, and the SEPTA Silverliner V are all 3.2 meters wide with sections of five-abreast seating). Why Caltrain hasn't already pursued this is baffling, because it is a low-cost and high-benefit change regardless of FTA rules. The Stadler KISS EMU that Caltrain ordered has previously been delivered in widths up to 3.4 meters. This design change is worth +64 seats per six-car EMU, or +256 seats/peak hour, or +7.5% core capacity.
   
• Increase the size of the initial EMU order.  This is a tough sell, given how hard it has been to fund the modernization project, but the relative cost increment is minor when considered in proportion to the entire budget. The Stadler contract already includes an additional 96 cars under a fixed-price option, 32 of which (one third) could be exercised to make all 16 of the EMUs on order eight cars long.  The incremental cost would be another $130M (one third of $390M, or less than 7% of the entire value of the PCEP project), and the seating capacity would go up by +186 seats per EMU, or +744 seats/peak hour, or +21.9% core capacity.  That's right: for an extra 7% cost you can triple the capacity increase.
   
• Both measures applied together would increase seating capacity by +272 seats per EMU, or +1088 seats/peak hour, or +32% core capacity (over and above the +10.7% capacity increase in Caltrain's FTA application).

The devil is of course in the details: changing the Stadler car shell is not free at this late stage of design, and lengthening trains to eight cars isn't just a financial headache but brings about awkwardness with certain platforms that are shorter than they ought to be.

Nevertheless, if it comes down to an existential issue of project eligibility, seat count nitpickers can undoubtedly be satisfied, and to everyone's benefit, by making a few basic adjustments. When a project's core capacity metric can be tripled for just 7% extra cost, it's a clear indication that it isn't an illegitimate fraud. Core capacity seat math either isn't an issue, or it can easily be resolved.

News Roundup, July 2015

Cost of Dual Height Boarding: with its industry review of the EMU draft RFP, Caltrain sought feedback from vehicle manufacturers regarding the cost and feasibility of delivering vehicles with dual boarding height capability.  According to the latest EMU procurement update, the feedback received indicates that vehicle cost would increase by just 3 to 5 percent.  This small premium (roughly $20 million) all but ensures that the HSR project will be able to pay for this important compatibility feature.

New Rules for Electrification: the California Public Utilities Commission has released General Order 176, the Rules for Overhead 25 kV Railroad Electrification Systems for a High-Speed Rail System.  The new GO, effective as of 26 March 2015, will also serve as the regulatory framework for Caltrain's electrification project, despite the peninsula corridor not qualifying as "high-speed rail" as narrowly defined in the document.  Three major issues remain to be hammered out with regulators and freight railroads: (1) grade crossing warning systems, (2) vertical clearances, and (3) freight personnel safety and training for operating freight trains in electrified territory.  These three issues are minor and unlikely to require a new rule-making process.  The release of GO 176 is timely for Caltrain's electrification project.

Cap and Trade Maneuvering: at least two lines of attack are being pursued by opponents of Caltrain electrification and the high-speed rail project.  First, there is or will be legal action that seeks to deny the use of Proposition 1A HSR bond funding to pay for Caltrain electrification, based on the (quite defensible) argument that electrification isn't high-speed rail and won't meet the legal restrictions of the bond measure. Prop 1A high-speed rail funding accounts for the lion's share of the funding package for electrification, a contribution of $600 million.  The underlying calculus is that denying this funding would kill the electrification project. Second, there is or will be legal action that seeks to deny the use of Cap and Trade funding to pay for high-speed rail, based on the (quite defensible) argument that the greenhouse gas reductions from HSR will only occur far in the future, well beyond the time frame required by CnT legislation.  Both of these legal challenges can be neutralized in one fell swoop, by substituting HSR CnT funds for the HSR Prop 1A funds. According to Caltrain's EIR, electrification will reduce greenhouse gas emissions by 80,000 metric tons per year initially, increasing to 190,000 metric tons by 2040, largely by cutting automobile traffic.  It doesn't get much more short-term than that, and CnT funds come with far fewer strings attached than Prop 1A funds.  Look for the funding swap to occur this fall, when the nine-party MOU is revised to reflect the growing electrification budget.

HSR Business Plan Machinations: due to the lack of funding to build the extremely expensive mountain crossings, there are indications that the 2016 business plan for HSR will call for service to begin in the SF and LA areas several years before the Central Valley is linked to anything.  This should be of some concern to Caltrain because it would put HSR in direct competition with Caltrain for affluent tech commuters, no matter what they say.  If Caltrain is elbowed out of the lucrative express market, the loss of revenue will be entirely HSR's gain.  While this Bay Area mini-HSR might show an operating profit (as required by law), it could only do so with a hidden subsidy, provided in the form of extremely scarce and valuable rush-hour track capacity.  Competition is great, but the market mechanisms for sharing the peninsula rail corridor "fairly" (whatever "fair" means to each stakeholder) would need to be carefully developed.  Then again, this silly idea might just wither on the vine, since the letters 'H' and 'S' would be absent from HSR.

Metrolink Scorns Electrification

Just like the peninsula corridor, the other end of California's planned high-speed rail network, in the Los Angeles basin, could also benefit from European-style "blended" service where electrified commuter trains and high-speed trains share tracks and stations.  Many of the solutions being developed by Caltrain for the peninsula corridor could also prove useful in the LA region, something that is not lost on rail supporters.  Paul Dyson, president of the advocacy group RailPac, recently wrote a letter to the relevant authorities expressing support for the idea of electrifying portions of the Metrolink commuter rail network to better integrate with high-speed rail.  His proposal is aptly named "Electrolink".

While the high-speed rail Authority seems all for it, the response (page 1, page 2) from Larry McCallon, Chair of the Metrolink Board of Directors, pours scorn on electrification in general and on Caltrain's project in particular.  Some highlights:

Cost.  Chair McCallon: "Caltrain's 51-mile electrification modernization project is currently projected to be between $1.45 and $1.5 billion (infrastructure and equipment).  Metrolink operates on over 500 miles of track which would make this option very cost-prohibitive."

Zing!  He does have a strong point, in that Caltrain's electrification project is probably the world's most expensive electrification program, per route-mile.  Caltrain can evidently afford pre-construction cost blowouts that Metrolink can't.

Schedule.  Chair McCallon: "Caltrain's experience shows them to be behind schedule in their 24th year of planning the electrification of their 51 mile segment between San Francisco and San Jose."

Double Zing!  He is of course referring to old studies of Caltrain electrification dating all the way back to the early 1990s, and pointing out that Caltrain's planning process is just now coming to fruition.  In Caltrain's favor, this is largely due to a lack of money and political will, and not to any technical obstacles.

Shared Corridors.  Chair McCallon: "Caltrain, even with very limited freight service on the San Jose to San Francisco line is struggling with electrification compatibility with freight trains.  Metrolink, on the other hand, operates on shared corridors with much more frequent Amtrak passenger and freight trains that carry some double stack cars.  The electrification vs. freight issues would only be compounded in these rail corridors.  Between Los Angeles and Fullerton our trains also operate on BNSF Railway owned lines."

This point is spot on.  The freight railroads are adamantly opposed to electrifying any tracks where they operate, even if they are not the owners of such track.  The last time that Caltrain tried to kick off a CPUC rule-making process to cover 25 kV electrification, in 2007 under CPUC docket P0706028, the process was promptly shut down by the freight railroads.  The CHSRA's effort to clear HSR electrification ran into similar opposition, and survives only because it explicitly sidesteps the issue of electrification over tracks used by freight trains.  While the contracting process for Caltrain electrification is well underway, on the regulatory front, we have... crickets.

Electrification versus freight is going to be a messy fight, one in which Caltrain appears to have no friends, least of all Metrolink.

Chair McCallon's lack of vision should be taken with a grain of salt: Metrolink is a struggling organization with sagging ridership, dodgy finances and a governance structure that makes Caltrain look like a well-run corporation.  Nevertheless, the underlying issue of compatibility with high-speed rail is at least as important down south as it is here on the peninsula.  Let us hope that Caltrain's blended system will blaze a good path for Electrolink to follow.

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.