SONOMA-MARIN AREA RAIL TRANSIT DISTRICT

VEHICLE TECHNOLOGY ASSESSMENT

FINAL DRAFT REPORT

Revised July 9, 2009

PREPARED BY

VEHICLE TECHNOLOGY ASSESSMENT

FINAL DRAFT REPORT
Table of Contents
1.0

EXECUTIVE SUMMARY ..................................................................................................... 1

1.1 Purpose ....................................................................................................................... 1
1.2 Approach ..................................................................................................................... 1
1.3 Summary of Findings .................................................................................................. 1
1.4 Conclusion................................................................................................................... 4

2.0

FRA REGULATORY ISSUES ............................................................................................. 6

2.1 Background ................................................................................................................. 6
2.2 Scope of FRA Jurisdiction ........................................................................................... 6
2.3 Temporal Separation ................................................................................................... 7
2.4 The Caltrain Situation .................................................................................................. 8

3.0

ADA: LEVEL BOARDING IMPLICATIONS ..................................................................... 10

3.1 ADA Level Boarding Requirements........................................................................... 10
3.2 Level Boarding Alternatives....................................................................................... 10
3.3 Low Level Platforms .................................................................................................. 13

4.0

VEHICLE TYPE COMPARISON ....................................................................................... 14

4.1 Introduction................................................................................................................ 14
4.2 Regulatory Compliances ........................................................................................... 15
4.3 Mechanical Parameters............................................................................................. 16
4.4 Operational Parameters ............................................................................................ 17
4.5 Energy and Fuel Consumption .................................................................................. 17
4.6 Emissions .................................................................................................................. 18
4.7 Availability of Proposers ............................................................................................ 19
4.8 Vehicle Cost .............................................................................................................. 19
4.9 Delivery Time ............................................................................................................ 20

5.0

CONCLUSIONS ................................................................................................................. 21
5.1 FRA Vehicle Design Requirements ........................................................................... 21
5.2 Buy America Compliance .......................................................................................... 21
5.3 Track Classification ................................................................................................... 21
5.4 Temporal Separation ................................................................................................. 22
5.5 Interoperability ........................................................................................................... 22
5.6 Recommendation ...................................................................................................... 22
LIST OF TABLES

Table 1:
Table 2:
Table 3:
Table 4:

Rev. 1

Synopsis of Alternate-Compliant DMU Shared Track Operation ................................. 8

Summary of Characteristics: Movable Bridgeplates and Gauntlet Tracks .................. 12
Vehicle Type Comparison ............................................................................................ 15
Operations Simulations ................................................................................................ 15

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1.0

EXECUTIVE SUMMARY

1.1

Purpose

The environmental assessment performed for the SMART rail corridor resulted in the
authorization of DMU (Diesel Multiple Unit) technology for the intended service. There are two
DMU technologies relevant to the SMART application; FRA (Federal Railroad Administration)
compliant DMU technology and alternate-compliant DMU technology. The purpose of this study
was to determine which of these two technologies would be best suited to the SMART
application.
1.2

Approach

The approach used was to perform a series of studies designed to make evident the significant
differences between the two DMU technologies, and, where possible, to identify the regulatory
constraints specific to each. To the extent possible, the study team also attempted to determine
the willingness of manufacturers to modify (or create) designs capable of meeting those
regulations. In this regard, the following studies were undertaken:

Implications of FRA Regulations for SMART Vehicle Technology Selection

ADA: Level Boarding Implications for SMART
Vehicle Characteristics Comparison

1.3

Summary of Findings

The Vehicle Characteristics Comparison report was the heart of the study and went deeper than
the title of the report may suggest. For example, this report contains comparisons of the two
candidate technologies from the following perspectives:

Regulatory compliance
Mechanical configuration
Operational performance
Energy and fuel consumption
Exhaust emissions profile
Proposer availability
Capital cost

Details regarding the results of each of these comparisons can be found in Section 4 of this
report; however, the key findings are summarized as follows:

The FRA will be the regulator of the intended service. Vehicles must be either fully FRAcompliant (may run intermingled with freight) or meet an FRA-defined level of alternatecompliance (may only run under an agreed-upon temporal separation arrangement, and
meet FRA mandated vehicle design requirements).

Implementation of PTC (Positive Train Control) in the U.S. is not presently sufficient to
allow the comingling of freight and alternate-compliant DMUs. It is noted that Caltrain is
pursuing a ruling from the FRA that would permit co-mingling of compliant and alternatecompliant passenger vehicles, but freight would still remain temporally separated. A
ruling to the effect that PTC alone would be sufficient to allowing co-mingling of freight
and alternate-compliant vehicles, if granted by the FRA, would be many years in the
offing, while SMART needs to firm up its technology decision by July of this year.

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Generally speaking, both vehicle types manifest a similar level of schedule performance
(approximately 1.5 hours each way), but those vehicles in the alternate-compliant
category achieve schedule performance with 41% less energy consumption and 37%
less fuel consumption on a per vehicle basis; however, the proposed FRA-compliant
vehicles will be larger than the proposed alternate-compliant vehicle. As such, an FRAcompliant DMU will provide about 50% greater passenger capacity, so the energy and
fuel consumption per seat between the two technologies is practically equivalent.

The estimated per-unit cost of an FRA-compliant DMU for a small fleet would be about
$8.5 million. The cost of an alternate-compliant DMU would be about $7 million.

The time to deliver the first car for an FRA-compliant DMU would be about 32 months.
The time to deliver the first alternate-compliant car would be about 26 months, although
there is some possibility of delay beyond this 26 months if SMARTs application for a
Buy America waiver is not granted by the time Federal funding is required, and the FRA
requires design modification to meet its definition of alternate-compliance, as was the
case in Austin.

Several manufacturers of potentially alternate-compliant, Tier 3 DMU designs were

identified:

There are no FRA-compliant DMUs in production, although several manufacturers have

produced conceptual designs for FRA-compliant DMUs. These manufacturers include:

Alstom (2 applicable models)

Bombardier (3 applicable models)
Ansaldo Breda (1 applicable model)
Siemens (1 applicable model)
One alternate-compliant DMU manufacturer, Stadler, recently offered a Tier 4
compliant design 1

Bombardier
CAF
Hyundai Rotem
Nippon Sharyo
Siemens
Brookville

Earlier versions of this report indicated that no builder of alternate-compliant vehicles would offer
SMART a vehicle meeting EPA Tier 4 emission requirements. Subsequent to the May 20 meeting of
the SMART Board of Directors, staff re-surveyed the industry and asked manufacturers for Letters of
Interest. At that time, Stadler responded that they will offer an alternate-compliant, Tier 4 vehicle in
time to meet SMARTs schedule. In further discussions with Stadler, they alleged that there had been
miscommunication within the company regarding SMARTs original inquiry. At that time, Stadler
representatives had misunderstood SMARTs timeline to be similar to that of the Denton County
Transit Authority, for which Stadler is supplying DMUs by 2012. Because the company will not have
Tier 4 vehicles available by that date for Denton, they responded to SMARTs initial inquiry saying
they could only provide Tier 3 vehicles to SMART. When the request for Letters of Interest went out in
late May, Stadler realized its mistake and responded that it will be able to supply Tier 4 vehicles to
meet SMARTs startup schedule for 2014.

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EPA Tier 4 regulations go into effect on January 1, 2011. All engines manufactured after
this date, with the exception of those which qualify under the Transition Program for
Equipment Manufacturers, or TPEM (explained below), must be Tier 4 compliant. To
date, we have only been able to identify one alternate-compliant carbuilder who will
commit to proposing a Tier 4 compliant design; consequently, if SMART requires an
alternate-compliant, Tier 4 design, there is a strong likelihood that there will only be one
proposer, Stadler.
There is an alternative approach to acquiring an alternate-compliant design (from an
EPA-compliance perspective), but this approach is not without risk. As noted above, the
EPA will allow diesel engine manufacturers to continue to manufacture Tier 3 engines
until 2018 under the following conditions:

Tier 3 equipment users would have a number of reporting requirements to the EPA
over the life of the engines

From 2011 until 2015, engine manufacturers may produce Tier 3 engines only as
long as the quantity of Tier 3 engines produced is 50% or less of their total
production run of engines in any given power range. Other uses in the DMU power
range (300 kW) would be construction (cranes, bulldozers, dump trucks, etc.) and
marine applications (ships, port facilities, etc.).

From 2015 until 2018, the production of all Tier 3 engines must be phased out.
Given the lack of new Tier 3 engines available beyond 2018, SMART could employ
a strategy wherein they purchased, say, two complete sets (shelf life would
prohibit purchasing more than two sets) of Tier 3 engines for each car prior to the
2018 deadline, if the engines were available to purchase. Since the practical
lifetime for these engines for the anticipated duty cycle would be no more than 5
years, a spare engine strategy could extend operations with Tier 3 equipment
until (approximately) 2028, about the mid-point of the vehicle lifetime. At that point,
SMART would have two choices:
i.

attempt to procure rebuilt Tier 3 engines in the requisite power range, should
a market for same evolve, and should they be available; or,

ii.

commence a re-engineering and re-manufacturing program, using Tier 4

engines, and adding all the necessary ancillary components needed to meet
the Tier 4 emissions requirements. This would include:

Increased cooling capacity

An SCR (catalytic) converter
Urea tank
Particulate filters
New, advanced controls

Both approaches introduce a considerable amount of risk which cannot be

mitigated at this time. A third possibility; i.e., that diesel engine technology in the
mid-2020s will have advanced to the point wherein they will be Tier 4 compliant
absent the need for selective catalyst reduction (SCR) and/or exhaust after
treatments, also exists, but relying on this outcome introduces even more risk.

Rev. 1

The FTAs Buy America rules require that agencies using Federal funds for railcar
purchases buy vehicles that have a minimum of 60% domestic content, and are
assembled in the United States. Each of the potential FRA-compliant DMU
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manufacturers noted previously are presently meeting this requirement on other
projects, and, if interested in the SMART vehicle procurement, could likely meet the
requirement here as well. The potential alternate-compliant offerings, both Tier 3 and
Tier 4, are all based on existing European designs, none of which are Buy Americacompliant. To change an existing design to a Buy America-compliant design is a
significant effort. No potential alternate-compliant DMU manufacturers willing to do this
have been identified.

Generally speaking, since FRA-compliant vehicles are designed to a higher longitudinal

compression strength (800,000 lbs.) than typical alternate-compliant DMUs (300,000 to
400,000 lbs.), the compression load must be carried by linear structural members,
known as center and side sills, through the length of the train. It would be difficult and
costly to interrupt the linearity of these beams in a single-level DMU in order to provide a
low (24) floor entry. Circumventing the FRA-mandated fuel tank design would also add
complexity. As a consequence, FRA-compliant cars are designed to a high platform
(51) floor height. This could require both architectural and right-of-way mitigation
measures at some historic stations along the alignment.

Interoperability with adjacent railways which are part of the General Railway System of
Transportation, such as Capitol Corridor and Napa County-based excursion trains,
would be readily achievable with an FRA-compliant design, but not with an alternatecompliant design.

1.4

Conclusion

Generally speaking, an alternate-compliant car offers more operational efficiencies in

comparison to an FRA-compliant design on a per vehicle basis. In order for SMART to be able
to procure alternate-compliant rolling stock, however, the following must occur:

SMART must come to an agreement with the present freight operator for temporal
separation.

The alternate-compliant DMU provider must be willing and able to meet FRA-defined
conditions for alternate compliance. As we have found based on the experience in
Austin, these requirements are still evolving and are, in part, project specific, resulting in
change orders and delays.

If Buy America provisions apply to this procurement, then SMART must petition the FTA
for relief from this requirement. This could introduce program delay.

SMART must be willing to construct and maintain its track to tighter tolerances than
specified by the FRA class 4 track requirements. This would introduce additional cost.

Interoperability would either be very difficult or impossible to attain.

On the other hand, if SMART were to solicit FRA-compliant rolling stock:

Rev. 1

No temporal separation agreement would be necessary, allowing SMART maximum

operational flexibility as the service matures.
The vehicle would be designed to be FRA-compliant, hence no waivers would be
required.
Acquiring a Buy America vehicle would not be an issue.
Track Class 4 would be acceptable.
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Interoperability with other FRA-regulated services, such as Capitol Corridor, would not
be an issue.

Although selecting FRA-compliant technology means sacrificing some efficiencies, it untangles

many regulatory knots and would allow SMART to provide the voter-mandated commuter rail
service on schedule, and unencumbered by the constraints of temporal separation allowing for
uninterrupted service growth. All things considered, and based on the best information
available to date, the recommended technology selection is for FRA-compliant DMUs.

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2.0

FRA REGULATORY ISSUES

2.1

Background

The Federal Railroad Administration, or FRA, is a regulatory agency of the Federal

Government, administratively part of the U.S. Department of Transportation. The FRA has
some historical antecedents traceable to the early regulation of the railroad industry in the 19th
Century, but the FRA in its present form was created with the establishment of the U.S.
Department of Transportation in 1966. While it does have other functions, the primary purpose
of the FRA (the one which makes it relevant to this study) is the development and enforcement
of railroad safety regulations. Many of these regulations specify in some detail the physical
design and method of operation of passenger equipment used on railroad lines.
The FRA issues regulations governing many aspects of railroad system design, construction
and operation for all trains, freight and passenger, which are part of the General Railroad
System of Transportation. Prominent among these are the regulations governing the safety of
railroad passenger rolling stock, including DMUs. These regulations provide very rigid
construction standards for passenger rolling stock. Rolling stock meeting these requirements is
termed FRA-compliant. Application of these construction standards results in greater vehicle
weight, surpassing that of alternate-compliant DMUs. Alternate-compliant DMUs use a different
philosophical approach to achieving passenger safety. Though not as structurally rigid as
FRA-compliant cars, alternate-compliant DMUs are typically designed to European crashworthiness standards EN 12663 and EN 15227. Cars built to these standards are designed to
absorb energy in an impact, rather than transmit impact energy through the structure. Also,
typically, European DMUs are operated in an advanced-signal environment, the concept being
more one of accident avoidance than accident survivability.
2.2

Scope of FRA Jurisdiction

A continuous topic of discussion is the nature of FRA jurisdiction relative to the jurisdiction of
state agencies over rail transit safety. In very general terms, one can say that passenger
services operated over railroad tracks, whether publicly or privately owned, fall under FRA
jurisdiction. In contrast, safety regulations of rail transit systems, such as light rail or rapid
transit (e.g. MUNI or BART) is left to the states. Specific oversight varies from state-to-state,
but in California, the agency responsible for rail transit safety is the California Public Utilities
Commission (CPUC).
This would seem relatively straightforward, but there are occasions upon which the distinction is
blurred. In these cases, one key criterion is whether or not the tracks are part of the General
Railroad System of Transportation. Absence of a track connection to the general railroad
system does not in and of itself affirm that FRA lacks jurisdiction, but the presence of a
connection, and the operation of the line as part of that system, as shown by the presence of
through freight traffic, assures the validity of FRA jurisdiction.
These matters have become an issue in cases where there has been a desire to introduce
alternate-compliant DMU vehicles onto tracks that are used at some point by freight trains. The
FRA has made it clear that it retains jurisdiction in such cases, but that waivers from some
requirements may be granted under proper conditions, of which the key provision is an absence
of simultaneous, co-mingled operation of FRA-compliant railroad equipment and alternatecompliant rail transit equipment.

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2.3

Temporal Separation

Trains operating in an FRA regulatory environment must comply with all FRA requirements.
FRA regulations can be found in a larger body of Federal rules known as the Code of Federal
Regulations. The Code of Federal Regulations, also known as the Code or CFR, is a
codification of the general and permanent rules published in the Federal Register by the
executive departments and agencies of the Federal Government. The Code is divided into 50
titles which represent broad areas subject to Federal regulation. Each title is divided into
chapters which usually bear the name of the issuing agency. Each chapter is further subdivided
into parts covering specific regulatory areas. Title 49 of the Code of Federal Regulations
addresses Transportation. Parts 200 through 299 of Title 49, published in a 900-page volume,
contain the regulations of the Federal Railroad Administration. References in this study,
formatted as 49CFR209 for example, refer to these regulations and their part and subparts
specifically.
With regard to vehicles, the FRA requires that all rolling stock operating in an FRA-regulated
environment must be designed and built to certain standards, as given in the 49CFR document.
That section of 49CFR which bears directly on the crux of the SMART DMU feasibility question
is 49CFR238: Passenger Equipment Safety Standards or Part 238 for short. Subpart C of
this section, dealing with Specific Requirements for Tier I Passenger Equipment, comprising
subsections 221 through 237, incorporates requirements for equipment, including DMUs
operating at less than 125 mph (Tier 1) on segments of the General Railroad System of
Transportation, which would include the entirety of the SMART alignment. Key provisions of
this subsection, which, typically, are not met by alternate-compliant DMUs, include:

Subsection 238.203, Static End Strength, which requires that vehicles resist a static
end load of 800,000 pounds without permanent deformation

Subsection 238.205, Anti-Climbing Mechanism, which requires anti-climbers at both

ends capable of resisting an upward or downward vertical force of 100,000 pounds
without failure.

Subsection 238.211, Collision Posts, which requires collision points at the one-third
points of vehicle width, laterally, with an ultimate longitudinal shear strength of
300,000 pounds

Subsection 238.213, Corner Posts which requires full-height corner posts capable of
resisting 150,000 pounds at the point of attachment to the underframe without failure.

Subsection 238.223, Locomotive Fuel Tanks, specifies fuel tank construction standards
typical of mainline locomotives, but also applying to DMUs.

Under certain circumstances, however, the FRA will allow alternate compliance; that is,
compliance to an alternate set of vehicle design standards. In order to be allowed alternate
compliance, both the passenger operating agency and the freight railroad sharing the alignment
must reach a temporal separation agreement, wherein the freight and passenger trains are each
given a dedicated window in time in which they operate exclusively. These windows are
separated by smaller, buffer windows, to insure that there will be no overlap in freight and
passenger operations. The FRA must grant a waiver from full compliance in order for the
passenger agency to operate under alternate compliance rules.

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Since its initial application to electrified LRT systems using shared track, the FRA waiver
process has been extended to projects planning to use the same tracks both for alternatecompliant DMU trains and heavy freight trains. The first of these projects, New Jersey
Transits 34-mile RiverLine linking Camden and Trenton, opened in 2004. Vehicles built to
European railway structural requirements, enhanced by front-end designs applying crash
energy management principles, initially had access to the shared portion of the route, about 32
miles, from 6:00 AM until 10:00 PM, when the shared section had to be vacated to allow for
overnight freight operations (temporal separation). In the years since, with a process analogous
to that in San Diego, which led to modifications of the rigid separation of the two services, NJT,
Conrail (the freight operator) and FRA have agreed to a series of adjustments that have
maintained the freight time window, while allowing a very limited expansion of the DMU
passenger service. These adjustments are highlighted in Table 1 below, which also lists two
additional DMU lines: the 22-mile Sprinter between Oceanside and Escondido in northern San
Diego County (nearing its first anniversary) and Capital Metros 32-mile Metrorail line, expected
to begin serving Austin, TX sometime in mid-2009.
Year

Property

State

Transit

Dispatch
Control

Synopsis of Waivers Effect

2004

NJ Transit RiverLine

NJ

DMU

Transit

Day/evening DMU; late night freight (contract freight operator)

2004

NJ Transit RiverLine

NJ

DMU

Transit

Above modified to allow early AM DMU north of Florence, w/freight to south

2005

NJ Transit RiverLine

NJ

DMU

Transit

Add early AM service Cinnaminson-Camden

2006

NJ Transit RiverLine

NJ

DMU

Transit

Extend last northbound trip from 26th St to Pennsauken/Rte 73 Park-Ride

2006

NJ Transit RiverLine

NJ

DMU

Transit

Early AM & late PM service, Burlington to Camden & Trenton

2007

NJ Transit RiverLine

NJ

DMU

Transit

Modified track/signals to support expanded late evening DMUs north to Pennsauken/

Rte 73

2008

NCTD Sprinter

CA

DMU

Transit

Day/evening DMU; late night freight (contract freight operator)

2009

Capital Metro Rail

TX

DMU

Transit

Day/evening DMU; late night freight (contract freight operator)

Table 1: Synopsis of Alternate-Compliant DMU Shared Track Operation

2.4

The Caltrain Situation

Possible simultaneous use of tracks by FRA-compliant trains and those alternate-compliant

DMUs under consideration in this study is an issue that arises repeatedly across the United
States. Recent studies are now underway with the intent of examining the possibility of
establishing alternative approaches to safety, while permitting more flexible employment of
technologies new to this country. It will likely be some time (years) before we see any
significant changes in the FRAs regulatory framework, however.
One property where the study of new technological approaches is under way is in the Bay Area
at Caltrain. Caltrain is the marketing label applied to the regional rail service operated between
San Francisco, San Jose and Gilroy by the Peninsula Corridor Joint Powers Board, an agency
formed through a joint exercise of powers agreement of San Francisco, San Mateo and Santa
Clara Counties. Under contract to the JPB, the San Mateo County Transit District provides
administrative services and contract oversight. Formerly the Southern Pacific Peninsula
Commuter Service, Caltrain has been significantly upgraded, and its popular Baby Bullet trains
provide the Bay Areas fastest scheduled transit service.
The Caltrain Corridor has been selected as the route for High Speed Rail to enter San
Francisco. For this reason, and to accommodate faster, more frequent service, Caltrain is
investigating the possibility of a phased conversion into an electrified regional rail service, using
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European-standard double-deck electric multiple unit (EMU) trains, consistent with California
High Speed Rail equipment.
If ultimately permitted, this would allow Caltrain to use rail vehicles that would not be compliant
with current FRA regulations, substituting international crashworthiness standards for same.
Freight service, currently minimal on the Peninsula, would be restricted to early morning hours
through temporal separation. This is essentially the present type and level of service. Some
FRA-compliant passenger service might be retained in this concept, however, through the
retention of diesel-powered Altamont Commuter Express (ACE) commuter trains and Amtrak
service on the short shared segment between Santa Clara and San Jose; and, possibly, the
reintroduction of passenger service between San Francisco, San Jose and Monterey Bay points
(Monterey and Santa Cruz).
The potential co-mingling of FRA-compliant passenger trains and alternate-compliant passenger
trains on the Caltrain alignment has led to a detailed technical study involving both Caltrain and
the Federal Railroad Administration. The FRA presently approaches safety through
requirements for conventional signals, and, based on the assumption that accidents will occur
through some failure of (or failure to observe) the signal system, also requires a massive
approach to construction for collision-survival. In the Caltrain concept, the proposed approach
is somewhat different: Caltrain is proposing an advanced train movement system in concert
with a Crash Energy Management (CEM) vehicle structure design that could provide passenger
survivability equal to or better than that provided by current FRA construction requirements.
Temporal separation would still apply to freight, but, as noted, the co-mingling of both FRA
compliant and non-compliant passenger trains is also being considered.
A preliminary detailed CEM evaluation of a candidate Electric Multiple Unit (EMU) has
demonstrated (via calculation) crashworthiness protection equivalent or better to that provided
by conventional FRA construction regulations, although a final decision by the FRA to fully
sanction this concept, implement new rulemaking through the comprehensive federal
procedures, conduct a trial installation and test period, determine whether or not full gradeseparation may be required and whether FRA-compliant passenger trains might be permitted is
far from completion. If SMART intends to commence design of its selected-technology DMU by
mid-summer of 2009, there is no chance that the Caltrain study will be completed in time to be
used as a precedent to justify the introduction of alternate-compliant DMU equipment absent the
need for temporal separation. Benefit may eventually be derived from the Caltrain work, but it
appears that it will be useful only in the longer term.

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3.0

ADA: LEVEL BOARDING IMPLICATIONS

3.1

ADA Level Boarding Requirements

Design and operating requirements for new and renovated facilities and public transportation
vehicles are contained in several parts of the Code of Federal Regulations (CFR), including:
36 CFR Ch. XI, Part 1192 ADA Accessibility Guidelines for Transportation Vehicles
49 CFR Subtitle A, Parts 37 Transportation Services For Individuals With Disabilities
(ADA) and 38 ADA Accessibility Specifications for Transportation Vehicles

Section 37.1 sets the standard for newly constructed public transportation facilities, which must
be readily accessible to, and usable by, individuals with disabilities, including individuals who
use wheelchairs. In regard to the correlation of railroad passenger car entries and station
platforms, often referred to as the car/platform gap, Section 38.113 of 49 CFR is specific in its
requirements:
TITLE 49TRANSPORTATION, Subtitle A--Office of the Secretary of Transportation, PART 38_AMERICANS
WITH DISABILITIES ACT (ADA) ACCESSIBILITY SPECIFICATIONS FOR
TRANSPORTATION VEHICLES, Subpart F_Intercity Rail Cars and Systems
Sec. 38.113 Doorways.
(d) Coordination with boarding platforms--(1) Requirements. Cars which provide level-boarding in stations with high
platforms shall be coordinated with the boarding platform or mini-high platform design such that the horizontal gap
between a car at rest and the platform shall be no greater than 3 inches and the height of the car floor shall be
within plus or minus 5/8 inch of the platform height. Vertical alignment may be accomplished by car air suspension,
platform lifts or other devices, or any combination.
(2) Exception. New cars operating in existing stations may have a floor height within plus or minus 1-1/2 (1.5)
inches of the platform height.
(3) Exception. Where platform set-backs do not allow the horizontal gap or vertical alignment specified in
paragraph (d) (1) or (2), platform or portable lifts complying with Sec. 38.125(b) of this part, or car or platform
bridge plates, complying with Sec. 38.125(c) of this part, may be provided.
(4) Exception. Retrofitted vehicles shall be coordinated with the platform in existing stations such that the
horizontal gap shall be no greater than 4 inches and the height of the vehicle floor, under 50% passenger load,
shall be within plus or minus 2 inches of the platform height.

3.2

Level Boarding Alternatives

Similar requirements apply for FRA-compliant and alternate-compliant vehicles. In both cases,
new FTA/FRA rules require that all doors be ADA accessible, ruling out mini-high platforms or
wheelchair lifts. If FRA-compliant passenger cars are selected for the SMART application,
entries will be 51 above the rail, and station platform edges can be no closer than 8 feet to the
track centerline. If alternate-compliant cars are selected with entries approximately 24 above
the rail, station platform edges can be no closer than 7 6 to the track centerline. It is these
dimensions that led to the installation of yellow movable platform bridgeplates at the Sprinter
DMU stations in northern San Diego County. These devices rotate through 90 degrees from
vertical to horizontal, and require trains to stop with sufficient precision that doors always align
with the bridgeplates. Because temporal separation is used, freight trains run only at night
when Sprinter is not operating, so the bridgeplates only need to be moved twice a day; that is,
lowered at the end of the Sprinter service day, and raised after the freight train has cleared the
line early the next morning.

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Sprinter Platform Bridgeplate

raised for nighttime freight operation

A similar State of Oregon platform clearance

requirement was met by using gauntlet tracks
at stations on tracks shared by new Westside
Express (WES) DMUs and freight trains. The
gauntlet approach uses a set of controlled
switch points at each end of the station area
to divert stopping passenger trains to the
high-level platform, while switching freight and
non-stopping passenger trains to the main
tracks, with safe side clearances provided as
mandated by the applicable state laws. This
solution adds track and signal (switch
interlocking) costs to the project, but these are
proven components of railroad hardware and
electronics, so pose little technical risk and preclude the need for movable components as part
of the station platforms. This is critical to WES, because the system is designed to allow
intermingled passenger and freight train operations so that the freight operator can maintain
competitive service to its customers. In this operating environment, multiple daily raisings and
lowering of bridgeplates would have been a riskier and more cumbersome solution due to the
following:
WES Platform with Gauntlet Track

Potential for failure of bridgeplates

High maintenance due to frequent use
Potential for a bridgeplate inadvertently left lowered to be struck by a freight train

It is safe to assume that SMART will need to be designed to accommodate full level boarding
(all doors, all cars, ADA-compliant car/platform gap or bridgeplates), and that SMARTs station
platforms will be higher than 8 above the rail. Thus, the system will fall under the requirements
of CPUC G.O. 26-D, Sections 3.4 and 3.5 (even if the FRA is SMARTs regulator), and boarding
platforms will have to be set back from the main track.
It should be further acknowledged that NCRA, and its designated freight train contractor, NWP
Company, have asserted their preference for 24/7 freight train access to the SMART rail line.
Even if temporal separation of SMART passenger and NWP freight trains is adopted as service

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begins, the eventuality of future mixed freight and passenger operation should be recognized,
and facilities should be designed and built with this contingency in mind.
These factors, taken in concert, suggest the following design guidelines for SMART:
Platform and car floor height should be the same height above rail, to enable ADAcompliant level boarding
CPUC General Order 26-D platform clearance standards must be met
Technical, maintenance and operating risks should be minimized

The following table summarizes the characteristics of the two car/platform gap approaches
reviewed above (bridgeplates; gauntlet tracks) that permit level boarding while meeting G.O.
26-D clearances:
ACCESSIBILITY APPROACH

MOVABLE BRIDGEPLATES

GAUNTLET TRACKS

Existing Revenue Service

NCTD Sprinter

TriMet WES

Special or Standard Design

Specially designed for Sprinter

Standard hardware used by

other rail applications worldwide

DMU/Freight Temporal Separation

Yes

No

Frequency of Use

Daily; lowered once and raised

once

Used by every WES Train

Requires interlocked switch at

each end of each equipped station

No

Yes

Track Edge of Platform Fenced

Yes; except at bridgeplates

when lowered

No

Other Issues

Trash occasionally fouls

operating mechanism

Interlockings part of signal

system

Table 2: Summary of Characteristics: Movable Bridgeplates and Gauntlet Tracks

Based on the foregoing, it is concluded that the gauntlet track option better represents proven
technology suitable for use on a rail line that, either initially or eventually, is likely to host
simultaneous passenger and freight train operations. Pending further analysis as the vehicle
identification and selection process proceeds, it is tentatively recommended that SMART design
proceed on the basis that gauntlet tracks be installed at each station platform located on a track
that will be shared by passenger and freight trains.

High Level Platform for Portlands WES DMU Service

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Passengers Boarding a WES Train

3.3

Low Level Platforms

Low level, 8 high platforms cannot be used along the SMART alignment. No DMU is equipped
to provide level boarding at this height. Also, none of the FRA-compliant or alternate-compliant
vehicles are designed to accommodate wheelchair lifts; hence, this eliminates stairwells as a
passenger boarding option.

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4.0

VEHICLE TYPE COMPARISON

4.1

Introduction

As noted in the Executive Summary of this report, the purpose of this study is to make an
assessment as to which technology, FRA-compliant or alternative-compliant, would best suit the
SMART application from a variety of perspectives. In order to develop a genuinely meaningful
basis for comparison, a number of parameters for each of the two candidate vehicle types were
investigated. These parameters include the following:

Regulatory Compliances
Mechanical Parameters
Operational Parameters
Environmental Parameters
Procurement Factors
Diesel Fuel Consumption
Emissions (Tier 3)
Emissions (Tier 4)

Results from investigations in each of the above categories are summarized in the following
tables: Table 3, Vehicle Type Comparison, and Table 4, Operations Simulations.
ALTERNATE-COMPLIANT DMU

FRA-COMPLIANT DMU

SMART PREFERENCE

REGULATORY COMPLIANCES
FRA
Requires Alternate FRA
compliance with waivers

Fully FRA-compliant

To be decided

CPUC

GO 143B

No

To be decided

ADA

Comply

Comply

Comply

Crashworthiness

EN12663 & EN 15227

FRA

EN standards preferred,
but not required

MECHANICAL PARAMETERS
Standards
US and/or European

US

Depends on vehicle

Configuration (per unit)

Articulated

Married-pair

No preference

Seats

~100

150 170

To be decided

Required buff strength

340,000 lbs.

800,000 lbs.

Depends on vehicle

Weight (empty)

150,000 to 160,000 lbs

300,000 to 320,000 lbs.

Lower weight

Average axle load AW2

~40,000 lbs.

~ 50,000 lbs.

Lower axle load

Length

130 140 feet

150 170 feet

< 150 feet per unit

(station length limits)

Width

9.7 feet

10 feet

To be decided

Floor height

~ 24

51

Low floor preferred

Carbody

Aluminum

Stainless Steel

No preference

Maximum speed

75 mph

79 mph

>= 75 mph

Track classification required

5 (maximum vertical deviations

controlled to 6)

To be decided. Lower for

cost; higher for ride quality

Powered axles

2 or 4 out of 6

4 out of 8

No preference

Propulsion

Diesel-electric or hydraulic

Diesel-electric or hydraulic

Diesel-electric preferred

Engines per unit

2-4

Typical total engine power

600 kW

1300 kW

Less required power

preferred (assuming no
impact to schedule)

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ALTERNATE-COMPLIANT DMU

FRA-COMPLIANT DMU

SMART PREFERENCE

OPERATIONAL PARAMETERS
One way trip at AW2

1:28 hrs

1:30 hrs

N/A

Vehicles needed for service

13

11

As required

Level boarding platform

height
Minimum platform gap

24

51

Low platform preferred

Bridge plates and gauntlet

track, or movable platform
edges

Bridge plates and gauntlet

track, or movable platform
edges

Gauntlet tracks

Temporal
with PTC

None

To be decided

ENVIRONMENTAL PARAMETERS
Emission compliance
EPA Tier 4

EPA Tier 4

EPA Tier 4

Typical exterior moving noise

emissions at 100 feet

Typical as measured:
Less than 75 dBA

FRA regulation:
Less than 90 dBA

Less than 75 dBA

Service History

In service in Europe and US

Design studies

Service proven

Critical path

Adaptation of existing designs

to EPA Tier 4 compliance and
receipt of required waivers.

New vehicle design

N/A

32 months

26 months

$8.5M

Lower cost

Deployment restrictions

separation,

even

PROCUREMENT FACTORS

Estimated delivery time

NTP to delivery of 1st vehicle

26 months

Estimated costs per vehicle

$7M

1)

1)

Does not consider the time needed for a Buy America waiver

Table 3: Vehicle Type Comparison

Stadler DMU
CapMet, Austin

CRM DMU
TriMet, Washington County

Estimated SMART
FRA-Compliant DMU

DIESEL FUEL CONSUMPTION

Vehicle configuration
6 axles articulated

4 axles single DMU

AW2 passenger load

200

150

300

Estimated round trip time at

vehicle weight AW2

3:00 hrs

2:56 hrs

3:04 hrs

Max. energy consumption

8.2 kW/h per mile

9.2 kW/h per mile

14 kW/h per mile

Total fuel consumption*

79.5 gallons

90.2 gallons

126 gallons

Gallons per mile

0.57

0.65

0.9

Miles per gallon

1.75 mpg

1.54 mpg

1.10 mpg
6,825 grams

EMISSIONS
CO

3,999 grams

4,887 grams

PM2.5

11 grams

282 grams

NOx+ NMHC

688 grams

5,638 grams

8 axle married-pair

20 grams
1,175 grams

Note: All values are applicable for one round trip between Larkspur and Cloverdale

Table 4: Operations Simulations

4.2

Regulatory Compliances

FRA-compliant cars will have no regulatory issues since they are, by definition, compliant with
FRA regulations.
The selection of an alternate-compliant design, however, could be
problematic from a regulatory perspective in that, as we have found in Austin, Texas, there is no
clear-cut FRA definition of alternate compliance. In Austins case, the definition of alternate
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compliance was a work in progress, necessitating a fairly continuous dialogue between Capital
Metro (Austins operator) and the FRA. .
4.3

Mechanical Parameters

Generally speaking, the investigation of the mechanical properties of the two different DMU
technologies has produced results consistent with expectations; that is, the FRA-compliant
design is heavier and structurally more rigid than the alternate-compliant design. This is a direct
result of the two different regulatory environments the vehicles were designed to operate in. It
should be noted that single-level FRA-compliant vehicles typically have a floor height of
approximately 51. A 51 floor height is needed to accommodate the trucks, drawbar and
coupler gear at the ends of the car. Alternate-compliant cars can drop the floor height to
approximately 24 inside of the trucks, but it is difficult to do this with an FRA-compliant singlelevel vehicle design in that the load path from coupler-to-coupler is best kept linear (no turns or
drops) to more easily develop the FRA requisite 800,000 lbs. buff strength, and to avoid
intersection with the fuel tank designed and constructed to FRA standards, which consumes a
significant amount of undercar space. It is for this reason, plus market considerations (level
boarding is vastly preferred over stairwells), that carbuilders prefer not to provide stairwells and
lifts, although some said they could be provided if required. Additionally, although low-floor
(24) double-deck, FRA-compliant vehicles (non-powered coaches) have been designed, it is
unlikely that any of those carbuilders proposing FRA-compliant DMUs would be interested in
providing either a powered low floor double-deck or low-floor single-level design for a relatively
small order. It must be realized that the carbuilders interested in proposing an FRA-compliant
design to SMART will be leveraging this opportunity to develop a prototype for future (nonSMART) market sales. The market they are targeting is for single-level, high-platform DMUs,
for applications throughout the U.S.
The fact that FRA-compliant DMUs are two times as heavy as alternate-compliant DMUs is
evidenced by the fact that the Colorado Railcar DMU used in our computer simulation requires
approximately 1300 kW of engine power, while the Stadler GTW alternate-compliant design
requires only 600 kW.
Another difference between the two candidate designs is in the configuration and length of a
standard operating unit. FRA-compliant vehicles are typically configured as married-pairs; that
is, two cars, with two trucks each, semi-permanently coupled together. Most manufacturers
have indicated that the cars of the married pair will be provided in a standard U.S. passenger
rail car length of 85 feet (170 feet for the married pair). Manufacturers have also indicated that
they can add a third car to the center of the married pair, making it into a triplet. This center car
could be configured without operator cabs. Passengers may pass through the couplings of the
cars within the married pair or triplet. Cars in a married-pair configuration can also be operated
independently, but they only have the operators cab on one end. Although there are many
advantages to this arrangement, one disadvantage is that the length of a married-pair could
exceed 150 feet as noted above. A two-unit train (consist) would then exceed 300 feet in
length, longer than SMARTs desired maximum platform length. Triplets, however, would only
be 255 feet in length.
Alternate-compliant DMUs are typically configured as articulated units; that is, two passengercarrying compartments with a center section acting as a hinge for the two passenger sections.
Typically, one truck is located directly under the center articulation, with an additional truck
located at each of the two non-articulated ends of each passenger section. Alternate-compliant
DMU units are less than 150 feet in length, so that a two-unit consist would be less than 300
feet in length.

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A final parameter of significance in this category for each of the two candidate technologies is
track classification. The classification of a track defines the amount of discreetly-sized
deviations, both vertical and horizontal, permitted in a specified length of track. The lower the
classification number, the more deviations are permitted. The higher the classification number,
the more comfortable the ride and the greater the permissible speed.
Track classification numbers in Europe are typically higher than they are in the United States, in
that the percent of passenger rail traffic as compared to all rail traffic is significantly higher than
in the U.S. It should be noted that European freight trains are much lighter than in the United
States. This is reflected in lower axle loads and shorter trains. This makes it easier to maintain
to higher track classifications. Additionally, Europeans have invested in a rail network of very
high speed (Train Grande Vitesse or TGV) passenger trains. Such operations command a
higher track classification, and the trucks for European alternate-compliant DMUs are designed
to be consistent with these classifications. As an example, the Oceanside-Escondido rail line
was built to a Class 5 and is only maintained to a Class 4. The trucks on the Siemens Desiro
had to be completely redesigned to accommodate this lower track classification. It is also noted
that speed on the Sprinter Line is limited to 55 mph, for a vehicle operated at 75 mph in Europe.
According to New Jersey Transit, they maintain their track on the River Line to Class 5, and
operate at up to 65 mph.
In the United States freight traffic dominates our rail network. Since passenger comfort is of
little concern in freight operations, track classifications are kept low to save money. Moreover, it
is difficult to maintain high track classifications under U.S. freight traffic, due to the reduced
emphasis on freight vehicle (wheel) maintenance, and the generally high weight of locomotives.
It is for this reason that FRA-compliant rolling stock (including DMUs) is designed to
accommodate lower track classifications, resulting in a softer, springy suspension.
4.4

Operational Parameters

In order to calculate certain operational parameters, such as run time and fleet size, it was
necessary to construct an operational (computer) model of the system, using actual DMU
performance characteristics (acceleration performance, braking rates, etc.) and the actual
SMART alignment and service parameters (length, grade, curves, civil speed restrictions,
station locations, headway, etc.). Two versions of Colorado Railcar DMU were used to simulate
an FRA-compliant operation. The first simulation was done with a single DMU and the second
one was done with a DMU and a coach to simulate a married-pair configuration, which will be
the most likely FRA-compliant DMU arrangement proposed to SMART. For the alternatecompliant DMU simulation, the Capital Metro (Austin) DMU was modeled. All passenger loads
were taken as an AW2 load, which is defined as all seats occupied and similar number of
passengers standing. The results indicated that both the FRA-compliant and the alternatecompliant designs can travel the length of the alignment (one way) in about 1.5 hours. When
the greater capacity of the married pairs is taken into account and the service plans are
adjusted accordingly, this translates to a fleet of 13 alternate-compliant cars or 11 FRA marriedpairs estimated to be required for SMARTs system 2 .
4.5

Energy and Fuel Consumption

In addition to the operations simulation described above, a second computer model of the
system was constructed. This model was used in a different simulation program one
designed to produce more technical outputs, such as energy consumption and emissions
generation. As in the operations study, real values for FRA-compliant (CRM) and alternate2

A previous estimate, developed prior to more detailed modeling, indicated approximately 14

cars for each vehicle type.

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compliant (Stadler GTW) DMUs were used, as well as actual SMART alignment parameters.
Summary level results of this simulation were as follows:

Energy consumption for an FRA-compliant married-pair DMU as proposed by

carbuilders for SMART was 14 kWh per mile. For a single car FRA-compliant DMU
(CRM), it was 9.2 kWh, while the energy expended by the alternate-compliant DMU was
8.2 kWh, about 32% lower than for a married-pair, FRA-compliant DMU.

Total diesel fuel consumed for the FRA-compliant, married-pair SMART DMU was 126
gallons per round trip, whereas the alternate-compliant vehicle used 79.5 gallons over
the same distance, about 37% less fuel. Factoring in the distance, this equates to 1.10
miles per gallon (mpg) for the FRA-compliant, married-pair SMART DMU, and 1.75 mpg
for the alternate-compliant design.

4.6

Emissions

Emissions were calculated at both Tier 3 and Tier 4 levels for all candidate technologies by
using the computer simulation program. Tier 3 results are not included now in this revised
report since, carbuilders for both vehicle types now indicate that they will propose Tier 4
compliant engines. Although the computer model doesnt directly output engine-specific
emissions levels, it assumes that the diesel engines are EPA compliant and calculates the
worst case (maximum EPA allowable) emissions based on the fuel consumed and the relevant
tier level. The maximum EPA-allowable emissions are used in that it is extremely difficult to
obtain a precise emissions profile from the diesel engine manufacturers. Typically, the only
information made available to the public is that the engines are compliant. It should also be
noted that the emissions results given in this report are conservative, in that engine
manufacturers will generally tailor exhaust output to minimize a specific pollutant, so long as the
other emissions are contained within the appropriate tier limits. Consequently, the actual
emissions levels should be no greater than the emission levels predicted in this report, and
possibly less. The emissions considered in this report are as follows:
CO:
Carbon Monoxide
PM10:
Particulate Matter (coarse)
NOx + NMHC: Nitrogen Oxide plus Non-Methane Hydrocarbons
In that the emissions produced are generally proportional to the fuel consumed, the ratio of
pollutants emitted by the FRA-compliant DMU vs. the alternate-compliant DMU will be in the
same rough proportion as the fuel consumed by each vehicle. For a typical round trip, the
alternate-compliant DMU will have a carbon foot print (carbon dioxide) which is 66% of that for
an FRA-compliant, married-pair DMU. Because of the higher capacity of the FRA-compliant
married pair, however the carbon foot prints are virtually the same when calculated on a per
seat basis.
The difference between the level of emissions between Tier 3 and Tier 4 is more dramatic. The
NOx + NMHC emissions are reduced by 85% from Tier 3 to Tier 4, while the particulate matter
(PM) emissions are reduced by 95%. Moreover, Tier 4 regulations require that all coarse
(PM10) particulate matter emissions be filtered out, allowing only a very small amount of fine
(PM2.5) particulate matter emissions in the exhaust.

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4.7

Availability of Proposers

No FRA-compliant DMUs are currently in production. Since FRA compliance is strictly an

American standard, there is no demand outside of the United States for cars of this design.
Additionally, DMUs designed to FRA standards are not attractive transportation solutions in the
world market. Typically, DMUs built to FRA requirements are heavier, and costlier, per vehicle,
than alternate-compliant designs. Offshore properties prefer the lighter and less costly
alternate-compliant DMUs found in Europe and elsewhere.
Regardless, some DMU
manufacturers see a niche FRA-compliant market emerging in the United States, and have
expressed interest in SMARTs comparably small order. Three carbuilders who have expressed
a fairly strong interest in providing an FRA-compliant DMU are Siemens (USA), Nippon Sharyo
(Japan), and Brookville (USA). CAF (Spain) has expressed moderate interest, and Hyundai
Rotem (Korea) has expressed a mild interest, as has Bombardier (Canada), but it is not
anticipated that either Hyundai Rotem or Bombardier would be willing to propose on a small 11
car fleet.
There are an abundance of alternate-compliant DMUs available in the marketplace, but there
are engineering (alternate FRA compliance), environmental (Tier 4), and commercial (Buy
America) constraints associated with this procurement which have significantly reduced
(probably to one) the number of candidate alternate-compliant DMU suppliers who would be
willing to propose to SMART. Although achieving a temporal separation agreement would most
likely allow SMART to obtain a waiver from the most restrictive FRA vehicle design requirement;
that is; the mandated 800,000 lb. compression end strength, there are a number of other FRA
engineering design requirements which would force alternate-compliant suppliers to change or
modify a portion of their designs. These would include:

Requirements for corner posts (structural)

Requirements for collision posts (structural)
Requirements for anti-climbers (structural)
Fuel tank requirements (structural)
Window glazing requirements
Flammability and toxicity (could necessitate major wiring and interior changes)

In addition unless SMART were willing to construct and maintain track to the levels required by
alternate-compliant vehicles designs, the trucks would have to be re-designed and/or the
maximum allowable line speed lowered.
Buy America requires 60% American components in the design, plus U.S. assembly of all but
the pilot car in the fleet. Again, starting from a clean sheet of paper, it would be possible for the
potential FRA-compliant DMU manufacturers to meet this requirement. Not so for the alternatecompliant manufacturers; to change their existing DMU platforms to incorporate 60% American
components would necessitate accommodating new subsystem outputs, dimensions, weights,
etc. To modify existing designs to such an extent for SMARTs small order would not make
good business sense. Based on conversations with the alternate-compliant carbuilding
community, none are willing to provide a Buy-America compliant design.
4.8

Vehicle Cost

The cost of an FRA-compliant car, for an order size of 11 cars, is estimated to be $8.5 million.
This estimate is based on the most recent cost of a Colorado Railcar DMU (no longer available),
plus the one-time non-recurring costs (engineering, tooling, production set-up, administration)
associated with a new product line.
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The estimated cost for an alternate-compliant DMU is $7 million. This is based on recent bid
prices plus escalation.
4.9

Delivery Time

Since no detailed design presently exists for an FRA-compliant DMU, it is anticipated that the
time from NTP to delivery of the first car would be about 32 months. The candidate FRAcompliant manufacturers generally agree with this estimate, but there is always some risk
associated with a new design; it could take longer.
Alternate-compliant designs are mature, and tooling already built (12 to 13 design-specific tools
are typical for alternate-compliant vehicles). It is estimated that that the time from NTP to
delivery of the first alternate-compliant car would take approximately 26 months, unless the
process is delayed by SMARTs petition for relief from Buy America, and the (likely) need to
modify the design to achieve FRA District 9s definition of alternate-compliance.

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5.0

CONCLUSIONS

Although alternate-compliance offers select technological advantages, such as reduced fuel

consumption per vehicle, a smaller carbon footprint and a potentially smoother ride (but only at
the expense of constructing and maintaining a higher track classification), the balance of the
evaluation factors favor the selection of FRA-compliant technology for the SMART application.
This conclusion is based, for the most part, on the following considerations:
5.1

FRA Vehicle Design Requirements

The FRA has a number of highly-specific, severe design requirements for vehicles operating
within the General Railway System. FRA-compliant DMUs will meet all of these requirements,
while most European DMUs meet none of them. An alternate set of design standards are
allowed (alternate-compliance) if temporal separation is implemented. While it is possible for
some European DMU builders to meet these alternate requirements, it is no simple matter to do
so. For example, the Austin car had undergone a number of design changes in order to meet
FRA-mandated vehicle safety standards. After at least a year of testing and modification, the
fleet finally is in simulated revenue service. SMARTs car order is only for 11-13 cars. It will be
difficult to interest the alternate-compliant carbuilders to bid on an order this size given the
number of design modifications the FRA is likely to insist on, even if the operating environment
includes both temporal separation and positive train control.
5.2

Buy America Compliance

Buy America regulations require that rail vehicles purchased by agencies using Federal funds
have a minimum of 60% domestic content, and that all but the first car be assembled in the
United States. As indicated previously, this will not be a problem for those carbuilders
proposing to supply FRA-compliant cars, but it constitutes a major issue for carbuilders with
existing alternate-compliant designs. To change a design from non-Buy America compliant to
Buy America compliant would be too extensive an effort to consider for an 11-13 car order. If
other decision factors point towards a recommendation for alternate-compliant technology, then
SMART will have to pursue a waiver from the Buy America requirements. In all likelihood,
SMART staff will have to wait until it is evident that all responders to the RFP have taken
exception to the Buy America provisions before they can petition the FTA for relief. If the waiver
process can be conducted in parallel with the design and construction of the first car, that is, if
SMART can obtain a Letter of No Prejudice in this regard, then there would probably be no
delay. This approach is not without risk, however; if the waiver is denied (unlikely, but possible),
then SMART would have two choices:
(1)

Forego federal funding; or,

(2)

Terminate the vehicle contract, pay the appropriate penalties, and re-advertise for an FRAcompliant car. This will add cost and introduce delay to the program.

Alternatively, SMART can petition the FTA for relief from Buy America before executing a
contact with the alternate-compliant carbuilder, but this will be cause for delay, and, possibly,
increased costs if the delay becomes lengthy.
5.3

Track Classification

European alternate-compliant DMUs are designed to run on rail networks with a relatively high
track classification. The primary reason for this is that European railways are, for the most part,
fast (>79 mph) and passenger-intensive as opposed to freight-intensive. Additionally, there is a
large high-speed rail network throughout Europe. Taken in combination, these factors lead to
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the need to construct and maintain the European rail infrastructure at a relatively high track
classification which leads, in turn, to a high ride quality. In the United States, however, heavy
freight dominates over rail passenger traffic. Since it is difficult (and expensive) to maintain
track subject to heavy freight traffic to the higher track classifications, American railroads are
typically operated at lower speeds and maintained to a Class 3, or, less likely, Class 4. FRAcompliant DMUs, which run exclusively on American railroads (the FRA only has jurisdiction in
the United States), will be designed to accommodate the lower track classification. If SMARTs
policy is to maintain their trackage to Class 4, this will not be a problem for FRA-compliant
DMUs. If, however, SMART selects alternate-compliant technology, they may have to construct
and maintain their track to some deviations similar to Class 6 (vertical deviations, for example).
This will introduce additional cost.
5.4

Temporal Separation

FRA-compliant vehicles are permitted to operate co-mingled with freight trains absent
restriction. Alternate-compliant DMUs, however, are not permitted to co-mingle with freight
trains. In order to operate on the SMART alignment, alternate-compliant DMUs must be
separated in time (temporal separation) from all other rail traffic. Negotiations in this regard
are presently ongoing between SMART and the freight operator. Although there is speculation
that the FRA may someday allow advanced train signaling in lieu of temporal separation, this is
not a ruling change that can be relied on in the context of making a prudent technology decision.
5.5

Interoperability

SMART has expressed a desire to eventually run select trains on other alignments which are
part of the General Railroad System of Transportation. Practically speaking, interoperability
on adjacent FRA-regulated alignment would not be achievable if alternate-compliant vehicles
are the selected technology. If FRA-compliant DMUs are purchased, interoperability with other
services within the General Railroad System of Transportation will be transparent. Examples
of opportunities for interoperability that would exist if FRA-compliant DMUs were the selected
technology include:

Excursion trains to Willits where connections to the famous Skunk Train would be
possible.

Excursion trains to Napa, where connections to the Napa Valley Wine Train would be
possible.

Access to the Capitol Corridor alignment, where connections to BART service at

Richmond, or Capitol Corridor trains to Sacramento would be possible.

5.6

Recommendation

SMARTs planned rail service lies within a perfect storm of American rail service regulators; that
is, the Federal Railroad Administration (FRA), the Environmental Protection Agency (EPA), and
the Federal Transit Administration (FTA). These three agencies, taken in combination, have
purview over the design, operation, environmental performance and funding of SMARTs rail
fleet. It is possible to specify a vehicle design and attendant commercial conditions which will
satisfy all the requirements of these agencies. A solicitation of this nature will attract at least
two proposers, either of which are capable of supplying a very high quality vehicle. This
approach has the highest probability of a successful project implementation.
An alternate approach would be to specify a vehicle design which is more efficient than in the
first approach, but which does not comply with FRA or FTA requirements; that is, a solicitation

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inconsistent with the known regulatory constraints.
efficient operation, but carries the following risks:

This approach could result in a more

Risk of attracting only one proposer (likely).

Risk of not achieving a temporal separation scheme adequate to sustain the intended
service levels in the near-, mid- and long-terms.

Risk of schedule delay as relief from the FTAs Buy America requirements are sought.

Risk of schedule delay in obtaining waivers from select FRA-required vehicle design
requirements.

Risk of sacrificing interoperability with adjacent FRA-regulated rail services.

Given the above, our recommendation is to maximize the likelihood of project success by
recognizing and accepting the regulatory environment in which SMART exists, and to develop a
set of technical and commercial procurement documents for FRA-compliant DMUs consistent
with this environment.
.

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