June 21, 2006
The Honorable Alan Lowenthal
Chair, Senate Transportation and Housing Committee
State Capitol, Room 2209
Sacramento, CA 95814
Attn: Art Bauer
(Download in Adobe PDF format)
Dear Chairman Lowenthal:
I have been asked by the California Transit Association to provide information to you as the Senate Transportation and Housing Committee for the State of California considers AB 1699, legislation that would restrict occupancy of the first 10 rows of commuter rail cab cars starting in 2007 and that would prohibit such cab cars from operating in a push configuration starting in 2010.
The push mode of commuter rail operations occurs when a locomotive pushes the train from the back; the cab car is in front with its attendant basic controls are operated by the engineer. When operating in the opposite direction, these trains are pulled by a locomotive, with the attendant operations performed from the locomotive. This type of operation is very common and widespread throughout the United States and around the world. Push-pull operations account for 64.5 percent of commuter rail passenger miles traveled in the United States. All eighteen commuter rail systems operating in the United States (including all four commuter railroads in California) use push-pull equipment for at least a portion of their operations, as will the two new systems which will begin operations this year in the states of New Mexico and Tennessee.
A July 1, 2005 interim analysis of push-pull operations performed by the Federal Railroad Administration (FRA), the federal regulator of railroad safety, found that the difference between the proportion of derailments occurring in the push mode and the pull mode is not statistically significant. Further, the study noted that severity outcomes in high-energy events are more likely to be influenced by chance circumstances rather than the placement of the locomotive. The FRA study showed that a person riding a push-pull commuter rail train is 25 times safer than a person riding in an automobile.
There are many things that can be done to enhance commuter rail safety, and the California commuter rail agencies are working hard toward those ends. The FRA and APTA are working together in research and testing of crash energy management designs (CEM) that will improve the crashworthiness of cab cars. Further, our members are
implementing crash-avoidance strategies that include median barriers, four quadrant gates, bells and lights, and signage and striping. In short, the assumption that cab cars are inherently unsafe and therefore need to be banned is simply incorrect.
Over the past decade, APTA has spearheaded the Passenger Rail Equipment Safety Standards (PRESS) Task Force, which works with the FRA to develop standards and regulations. As a result of the PRESS efforts, rail equipment safety in this country has improved and will continue to improve. These equipment safety standards are developed through a collaborative effort involving worker union representatives, FRA officials, equipment manufacturers, and commuter railroads.
Commuter rail service has been very successful in California and around the country. As America grows, commuter rail provides a safe and affordable option to millions of travelers. The legislation in question would confront California communities that have invested in such safe systems with the overwhelming burden and cost of changing to a full pull mode. Legislation such as this undoubtedly would be a huge setback in the development of economical, fuel efficient, environmentally friendly commuter rail services. It likely would put many lines out of business, thus putting riders back on congested, less safe highways.
Commuter railroads provide a safe, reliable and cost-effective mode of travel. Push-pull commuter rail operations are a significant part of this safety and reliability record.
If I may provide additional information as you consider this important topic, please feel free to contact me.
Sincerely yours,

William W. Millar
President
WWM/ajm
cc: Honorable Members, Senate Transportation and Housing Committee
Assembly member Dario Frommer
The American Public Transportation Association (APTA) is a nonprofit international association of more than 1,600 public and private member organizations including transit systems and commuter rail operators; planning, design, construction and finance firms; product and service providers; academic institutions; transit associations and state departments of transportation. APTA members serve the public interest by providing safe, efficient and economical transit services and products. More than 90 percent of persons using public transportation in the United States and Canada are served by APTA members.
Some of these pages may include links to documents in the Adobe PDF format. Please download the Adobe PDF reader if you have not already done so.