Petitions for Waivers of Compliance; Petition for Exemption for Technological Improvements

Federal RegisterAug 23, 1999

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DEPARTMENT OF TRANSPORTATION

Federal Railroad Administration

Petitions for Waivers of Compliance; Petition for Exemption for

Technological Improvements

In accordance with Title 49 Code of Federal Regulations (CFR)

Sections 211.9 and 211.41, and 49 U.S.C. 20306, notice is hereby given

that the Federal Railroad Administration (FRA) has received a request

for waiver of compliance with certain requirements of

[[Page 45997]]

the Federal railroad safety regulations and a request for exemption of

certain statutory provisions. The individual petition is described

below, including the party seeking relief, the regulatory and statutory

provisions involved, the nature of the relief being sought and the

petitioner's arguments in favor of relief.

New Jersey Transit Corporation; FRA Waiver Petition No. FRA-1999-

6135

New Jersey Transit Corporation (NJ Transit) seeks a permanent

waiver of compliance from certain CFR parts of Title 49, specifically:

part 221, Rear End Marking Device--Passenger, Commuter and Freight

Trains; part 223, Safety Gazing Standards--Locomotives, Passenger Cars

and Cabooses; part 229, Railroad Locomotive Safety Standards; part 231

Railroad Safety Appliance Standards; part 238, Passenger Equipment

Safety Standards; and part 239, Passenger Train Emergency Preparedness.

NJ Transit seeks approval of shared use and waiver of certain FRA

regulations involving light rail passenger operations on the planned

Southern New Jersey Light Rail Transit (SNJLRT) system. SNJLRT is a

regional light rail transit system that will link the cities of Camden,

NJ and Trenton, NJ, and provide local service along with bus, transit,

and intra and intercity rail transfer connections to an area previously

without light rail service. The SNJLRT project will cover 34 miles

using a combination of street running alignment and existing railroad

right-of-way to assist in meeting Southern New Jersey's mobility and

congestion needs.

A portion of the SNJLRT will run over the existing Consolidated

Rail Corporation (Conrail) Bordentown Secondary track, between MP 1.07

(Camden) and MP 33.1 (Trenton). The purpose of the waiver is for SNJLRT

operations over this ``Shared Trackage'' because of its connection with

the general railroad system of transportation. Conrail and NJ Transit

have agreed that transit operations will have exclusive use of the

Shared Trackage during the passenger period.

In each section entitled ``justification,'' FRA merely sets out NJ

Transit's justifications which are included in its petition. In doing

so, NJ Transit references the proposed Joint Policy Statement on Shared

Used of the General Railroad System issued by FRA and the Federal

Transit Administration (FTA) (64 FR 28238; May 25, 1999) (``Policy

Statement''). The proposed policy statement suggests that regulation of

light rail service on the general rail system, under conditions of

temporal separation from conventional rail movements, be handled

through application of complementary strategies. FRA regulations would

generally be employed to address hazards common to light rail and

conventional operations for which consistent handling is necessary,

while other hazards would be handled under FTA's program of State

Safety Oversight (49 CFR Part 659). See proposed Policy Statement for

details. Since FRA has not yet concluded its investigation of the

planned SNJLRT system, the agency takes no position at this time on the

merits of NJ Transit's stated justifications. As part of FRA's review

of the petition, the Federal Transit Administration will appoint a non-

voting liaison to FRA's Safety Board, and that person will participate

in the board's consideration of NJ Transits's waiver petition.

Part 221--Rear End Marking Device--Passenger, Commuter and Freight

Trains

Section 221.13(a) requires each train that occupies or operates on

main line track be equipped with a display on the trailing end of the

rear car of that train, and continuously illuminated or flashing a

marking device as prescribed in that subpart. Section 221.14(a)

requires that passenger, commuter and freight trains be equipped with

at least one such compliant marking device, which has been approved by

FRA in accordance with the procedures included in Appendix A of part

221, and which has specific intensity, beam arc width, color and flash

rate characteristics. The requirements are intended to reduce the

likelihood of rear-end collisions attributable to the inconspicuity of

the rear-end of a leading train.

Justification. NJ Transit requests a waiver from this requirement

because the SNJLRT vehicle will be equipped with marking devices such

as headlights, brake, tail, turn signal, clearance and marker lights,

and reflectors similar to those required for highway vehicles as

contained in NJDOT regulations. The NJDOT regulations adopt and

incorporate by reference the Federal Highway Administration's

(``FHWA'') Federal Motor Carrier Safety Regulations found at 49 CFR

part 393.

The external illumination consists of a set of front headlights,

turn signals, tail and brake lights, reflectors, clearance, and marker

lights at each end of the bi-directional SNJLRT vehicles. One headlight

is mounted next to each brake light, with the headlights capable of

being switched from low to high beam. Turn signal lights are visible

from both the front and sides of the vehicle. The mounting height and

candela value of the lights provided is consistent with FHWA

requirements for commercial motor vehicles contained in 49 CFR part

393. The SNJLRT vehicle exterior lighting was designed to match state

highway vehicle requirements instead of FRA regulations because the

SNJLRT vehicles will operate in two different environments: in streets

running mixed with motor vehicle traffic and in a conventional railroad

corridor. FRA-compliant rail car marker devices might not provide

sufficient information to motor vehicle drivers and, therefore might be

inappropriate for the in-street portion of the SNJLRT system. The

SNJLRT specifications on the other hand, will provide a higher level of

safety for in-street operations.

NJ Transit believes that safety on the conventional railroad

corridor will not be compromised by the use of the SNJLRT marking

devices. The SNJLRT vehicle will have tail and brake light and

clearance lights to define the end contour of the vehicle,

substantially similar to the marking devices required by FRA

regulations. Any variation in illumination levels between SNJLRT

vehicles and Conrail trains is not material because of the temporal

separation of the operations.

Section 223.9(c)--Glazing Requirements

Section 223.9(c) requires that passenger cars, including self-

propelled passenger cars built or rebuilt after June 30, 1980, be

equipped with FRA certified glazing in all windows. This requirement is

intended to reduce the likelihood of injury to passengers and/or

employees from breakage and shattering of windows (including

windshields).

Justification. NJ Transit requests a waiver of this requirement for

windows other than cab windshields because those windows will conform

to the side impact requirements of ANSI Z26. 1, Table 1, item 1,

``American National Standard for Safety Glazing Materials for Glazing

Motor Vehicles and Motor Vehicle Equipment Operating on Land

Highways.'' This glazing is break-resistant in normal usage, but can be

broken with a standard rescue tool, such as a pry bar (a pry bar will

be located near side windows in each SNJLRT vehicle) in an emergency.

Upon breaking, the glass ``crumbles'' into pebble-like pieces, posing

no significant hazard to passengers, employees or rescue personnel. The

use of such safety glass windows is standard throughout the rail

transit industry for (among other applications) in-street light rail

operations, where it has proved both durable and safe. In addition, the

risk

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associated with vandalism (such as by rocks thrown against the windows)

is addressed from an operations standpoint in the System Safety Program

Plan (SSPP).

Section 223.9(d)--Emergency Exit Window Markings

Section 223.9(d) requires that each emergency window be

conspicuously and legibly marked with luminescent material on the

inside of each car and that clear and legible operating instructions be

posted at or near each such window. This section also requires that

each window intended for access by emergency responders for extrication

of passengers be marked with a retroreflective, unique and easily

recognizable symbol or other clear marking and that clear and

understandable window-access instructions be posted at each such window

or at the end of each car. These requirements are intended to

distinguish emergency windows from other windows and provide

information on the operation of the emergency windows.

Justification. NJ Transit requests a waiver from these requirements

because all side windows on the SNJLRT vehicles are suitable for use in

the event of an emergency and therefore, it would make no sense and

could prove to be a confusion hazard to mark any particular side

windows as designated ``emergency windows.'' All side windows are made

of safety glass and are fitted into the sidewalls by large, specialized

rubber sections. All of these windows can be broken with standard

rescue tools and can function as emergency windows if necessary. Pry

bars, which can be used to break windows if necessary, will be located

near side windows inside each SNJLRT vehicle. Instructions meeting FRA

requirements and clearly indicating that the pry bar can be used to

break any side window will be posted adjacent to each pry bar. Thus,

identification of some windows as ``emergency windows'' and the posting

of special operating instructions is not appropriate in this instance

and is not necessary for safe emergency egress from the SNJLRT vehicle.

Enforcing the marking requirements would not serve the intended safety

purpose.

Section 223.15(c)--Emergency Window Requirements

Section 223.15(c) requires each passenger train car to be equipped

with at least four emergency windows designed to permit rapid and easy

removal during an emergency. This requirement is intended to enhance

safety by providing emergency egress, in addition to egress through

vehicle doorways.

Justification. NJ Transit requests a waiver of this requirement

because the SNJLRT vehicles will not be manufactured with designated

emergency windows. The vehicles, however, are designed to permit

equivalent or superior emergency exit options. Each vehicle has 10

windows on each side, all of which are made of safety glass and are

fitted into the sidewalls by large, specialized rubber sections. All of

these windows are large (approximately 42 by 36 inches) when compared

with conventional commuter rail cars, can be broken with standard

rescue tools, and can function as emergency windows if necessary.

Furthermore, the SNJLRT vehicle doorways provide greater access/

egress capability than is found on conventional commuter rail cars.

Each vehicle has two sets of double doors on each side of the vehicle.

The minimum clearance height of each doorway is 76 inches and the flow

lane width of each doorway is at least 24 inches (48 inches in total

for each set of double doors). The vehicle is designed such that the

egress time of an AW2 load shall not exceed 120 seconds, calculating

egress by assuring a flow rate of 2 seconds per passenger per flow

lane. The doors are releaseable through an emergency release lever

located on the inside of each doorway and for at least one doorway per

side on the outside of the vehicle. This will enable a closed and

interlocked door to be lock-released without power supply. Activation

of the emergency release levers shall allow the door leaves to be

manually operated. The interior door release levers shall be clearly

marked and in a location accessible to all passengers, compliant with

American with Disabilities Act (ADA) and FRA marking requirements.

These release lever features will enable quick and easy opening of the

doors by passengers, equivalent to FRA emergency exit window

requirements.

The doorways are designed to provide the main means of emergency

access/egress, and because the large windows can function as additional

emergency access/egress points, there is very little risk of passengers

becoming trapped or rescue personnel being unable to reach passengers.

In addition, the SSPP will contain detailed emergency response plan

requirements which will include passenger evacuation and crowd control

planning.

Section 229.125--Headlights and Auxiliary Lights

Sections 229.125(a) and (d) require locomotives to have headlights

of specified candela brightness, and auxiliary lights of specified

brightness and placement on the vehicle. The purpose of these

requirements is to reduce the risk of collisions attributable to

inconspicuity of the train, particularly in low light level situations.

Justification. NJT requests a waiver from these requirements

because the SNJLRT vehicles will have lights similar to those required

by state law applicable to commercial motor vehicles. The SNJLRT

vehicles will be equipped with two headlights on the leading cab of the

train capable of illuminating a person 500 feet away. In addition, each

vehicle will have an auxiliary light on the front of the car that will

form a triangular pattern with the headlights to present a distinctive

profile to motor vehicle drivers approaching grade crossings.

The use of lighting similar to motor vehicle lighting is desirable

because the SNJLRT vehicle operates in two distinctly different

environments. One portion is on mainline railroad track and the other

is street-running mixing with highway traffic. NJ Transit believes that

while the SNJLRT lighting arrangement will provide for sufficient light

to provide safety along the railroad right-of-way, the FRA lighting

requirements may not be appropriate for the street-running portions of

the route. However, since the front of the vehicle will have headlights

and auxiliary lighting to define the end contour of the vehicle, the

conspicuity of the train will be assured in both the Shared Trackage

and street-running portions of the route and any effect of variations

in illumination levels will be minor.

Section 231.14--Passenger Cars Without End Platforms

Section 231.14 specifies the requisite location, number,

dimensions, and manner of application of a variety of railroad car

safety appliances (e.g., hand brakes, ladders, handholds, steps),

directly implementing a number of statutory requirements found in 49

U.S.C. 20301-05.

The statutory provisions contains specific standards for automatic

couplers, sill steps, hand brakes, and secure ladders and running

boards. Where ladders are required, compliant handholds or grab irons

for the roof of the vehicle at the top of each ladder are mandated.

Compliant grab irons or handholds also are required for the ends and

sides of the vehicles, in addition to standard height drawbars. In

addition, the statute requires trains to be equipped with a sufficient

number of vehicles with power or train brakes so that the engineer may

control the train's speed without the use of a common

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hand brake. At least 50 percent of the vehicles in the train must be

equipped with power or train brakes, and the engineer must use the

power or train brakes on those vehicles and all other vehicles equipped

with such brakes that are associated with the equipped vehicles in the

train.

Aside from the statutory-based requirements, the regulations

provide additional and parallel specifications for hand brakes, sill

steps, side handholds, end handholds, end handrails, side-door steps

and uncoupling levers. More specifically, each passenger vehicle must

be equipped with an efficient hand brake that operates in conjunction

with the power brake on the train. The hand brake must be located so

that it can be safely operated while the passenger vehicle is in

motion. Passenger cars must have four sill steps and side-door steps,

and prescribed tread length, dimensions, material, location and

attachment devices for sill steps and side-door steps. In addition,

there are requirements for the number, composite material, dimensions,

location and other characteristics for side and end handholds and end

handrails. Finally, this section requires the presence of uncoupling

attachments that can be operated by a person standing on the ground.

These very detailed regulations are intended to ensure that sufficient

safety appliances are available and that they will function safely and

securely as intended.

Justification. As noted above, some of the requirements in

Sec. 231.14 are required by statute and, therefore, are not subject to

waiver under FRA's regulatory waiver provisions. FRA does, however,

have the statutory authority to provide exemptions from these statutory

requirements pursuant to 49 U.S.C. 20306. Consequently, NJ Transit

requests exemption from and/or waiver of these requirements, as

appropriate, because the SNJLRT vehicles will be equipped with their

own array of safety devices, resulting in equivalent safety.

The SNJLRT vehicle has a number of features that provide an

equivalent or superior level of safety as compared to a conventional

hand brake. Each SNJLRT vehicle will be equipped with a parking brake

located in each of the two control stands in each vehicle.

The brake is capable of holding the vehicle on a gradient of six

percent at an AWl (60 tons) load. The SNJLRT vehicles will be operated

by a one-person crew. The SNJLRT train will be either one or two

vehicles. The train will be operated from the control stand in the lead

cab, on trains consisting of two cars, and from the front of the single

vehicle in the case of a one vehicle train. During normal operating

conditions, the operator will make all service and parking brake

applications. In the event of an emergency, the SNJLRT vehicle will

have several features which would permit passengers to activate the

braking system. First, an emergency release device located on each

passenger door pillar causes an irrevocable application of the service

brakes in the event of any application. Second, the four doors (two on

each side of each vehicle) are interlocked with the propulsion system

to ensure that the SNJLRT vehicle does not move while any doors are

open, and the opening of the doors while the SNJLRT vehicle is in

motion will cause an irrevocable application of the service brake. The

braking characteristics of the SNJLRT vehicle will result in a shorter

full service brake activation time and easier brake application than

would be achieved by the presence of a traditional hand brake. Thus,

the safety purpose of the hand brake requirement is achieved, but in a

manner that provides an equivalent or superior level of safety.

Sill steps and side-door steps are not necessary for safety on the

SNJLRT vehicle, because it is a low floor vehicle designed for level

boarding. The door threshold is 22.4 inches above the top of the rail.

This configuration of the doors renders sill steps and side-door steps

unnecessary. Compliance with the sill step and side-door step

requirements would not enhance the safety of the vehicle.

Handholds and handrails are typically intended for use by

conductors and crew members performing service and yard duties.

However, SNJLRT operations will not involve any service and yard duties

from positions outside and adjacent to the vehicle or near vehicle

doors. Yard moves will be controlled from the cab stand by the on-board

operator and switches will be thrown remotely or through local controls

initiated by the on-board operator. Therefore, since there is no need

for personnel to mount or dismount the vehicle using external

appliances of any kind, there is no need for handholds or handrails on

SNJLRT vehicles. NJ Transit has reservations about installing external

handholds and handrails because of the street-running characteristics

of part of the SNJLRT service.

External handholds or handrails would give pedestrians the

opportunity to grab onto something on the outside of the vehicle with

the intention to get a ride. This is unsafe and the SNJLRT vehicle will

be designed to minimize the opportunity for this practice. In sum,

there is no practical need for handholds or handrails, and their

presence might constitute a safety hazard in the street-running

operating environment.

The SNJLRT vehicle will be equipped with a fully automatic electric

coupler controlled from the operator's position in the cab and a

mechanical coupler at each end. The coupler and associated draft gear

system will have a centering device that retains the unconnected

coupler head within its gathering range. The couplers are central

buffer couplings with electrical and pneumatic coupling. The operator

will initiate uncoupling from the cab stand and no external crew is

required to assist in this operation. NJ Transit believes that

performing all coupling/uncoupling from inside the vehicle will enhance

safety. This elimination of the need for frequent coupling/uncoupling

of vehicles, combined with the ability for such activity to take place

without crew members in close proximity to the coupler mechanisms,

eliminates the need for specially placed uncoupling levers and any

hazard associated with manual coupling.

The SNJLRT vehicles will use dynamic brakes. The dynamic brakes

will be supplemented by friction brakes and track brakes. NJ Transit

will require regular inspections, testing, maintenance and operation of

the brake equipment on the SNJLRT vehicle as required by Section 5 of

the NJDOT SSPP. Specific operational procedures and inspection testing

and maintenance intervals and protocols will be set forth in the SSPP.

Therefore, the SNJLRT vehicle brake system will be equivalent to a

standard air brake system and thus provide an equivalent level of

safety.

NJ Transit is aware that it may obtain exemption from the statutory

safety appliance requirements mentioned above only if application of

such requirements would ``preclude the development or implementation of

more efficient railroad transportation equipment or other

transportation innovations.'' 49 U.S.C. 20306. The exemption for

technological improvements was originally enacted to further the

implementation of a specific type of freight car, but the legislative

history shows that Congress intended the exemption to be used elsewhere

so that ``other types of railroad equipment might similarly benefit.''

S. Rep. 96-614 at 8 (1980), reprinted in 1980 U.S.C.C.A.N. 1156, 1164.

FRA has recognized the potential public benefits of temporally

separated transit use on segments of the general railroad system. Light

rail transit systems ``promote more livable communities by serving

those who live

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and work in urban areas without adding congestion to the nation's

overcrowded highways.'' Policy Statement at 28238. They ``take

advantage of underutilized urban freight rail corridors to provide

service that, in the absence of the existing right-of-way, would be

prohibitively expensive.'' Id. There have been many technological

advances in types of equipment used for passenger rail operations, such

as the use of light rail transit vehicles that will be used for the

SNJLRT System. Light rail transit equipment is energy-efficient for

passenger rail operations because it is lighter than conventional

passenger equipment. Light rail vehicles are able to quickly accelerate

or decelerate, which makes them more suitable than other equipment

types in systems with closely-configured stations.

With regard to the regulatory requirements of Sec. 231.14, as

discussed above, the SNJLRT vehicles will be equipped with safety

appliances that are more appropriate for light rail transit vehicles,

thus achieving an equivalent or superior level of safety in the SNJLRT

operating environment.

Section 238.113--Emergency Window Exits

Section 238.113 requires passenger cars to have a minimum of four

emergency exit windows, either in a staggered configuration or with one

located at each end at each side of the car. Each window must have a

minimum unobstructed opening with dimensions of 26 inches horizontally

and 24 inches vertically. Each emergency exit window must be easily

operable without requiring the use of a tool or other implement. This

requirement is intended to provide for sufficient, easily accessible

avenues of egress from passenger cars in the case of emergency.

Justification. NJ Transit requests a waiver of this requirement

because the SNJLRT vehicles do not come equipped with emergency exit

windows. The cars, however, are designed to permit sufficient

equivalent egress so that passengers will not become trapped in the

cars in the case of emergency.

Section 238.115(b)--Emergency Lighting

Section 238.115(b)(4) requires passenger cars to provide battery-

powered emergency lighting with a 90-minute back-up power system

capable of operating without a loss of more than 40% minimum

illumination levels in all equipment orientations within 450 of the

upright and vertical position, and capable of operating after the

initial shock of a collision or derailment resulting from prescribed

individually applied accelerations. The purpose of these requirements

is to ensure that in an emergency situation, sufficient lighting will

remain available to aid passengers, crew members, and rescue personnel

to access and leave the train safely.

Justification. NJ Transit requests a waiver of these requirements

because power for the emergency lighting is provided by a battery with

sufficient capacity to sustain emergency loads, including the above

lighting, and radio and public address systems, for a period of at

least one hour. Additionally, the battery will have sufficient capacity

to sustain power to door controls, propulsion and brake controls,

coupler control and the horn and bell for a period of at least one

hour. The battery is located in the central power unit, removed from

the front of the vehicle where direct collisions may occur. The battery

is designed for transit use which requires a rugged design capable of

withstanding reasonable shock and vibration. The batteries mountings

are designed to withstand not less than 5.0 g in the longitudinal

direction, 2.0 g in the lateral direction and 3.0 g in the vertical

direction.

The SNJLRT vehicles will operate in an urban/suburban region and

the route is at-grade, with many points of easy access for emergency

rescue units from adjacent streets. In most locations, emergency

responders can reach the SNJLRT system within 15 minutes. Even on the

most remote section of the system, a three-mile stretch along Duck

Island, emergency responders could reach the system within sixty

minutes. Additionally, the headway between SNJLRT vehicles is no more

than thirty minutes and each vehicle has the capability of acting as a

rescue car by coupling with a failed unit and moving it to the next

stop for detrainment of passengers. The rescuing car can supply

sufficient electrical power to the failed vehicle for the emergency

lighting and other functions. In the event that the last scheduled

vehicle of the day lost power, the previous vehicle would be returned

to recover the failed vehicle.

Section 238.203--Static End Strength

Section 238.203 provides for the overall compressive strength of

rail passenger cars, requiring them to have a minimum static end

strength of 800,000 pounds on a line of draft at the ends of occupied

volumes without permanent deformation of the car body structure. This

section is intended to prevent sudden, brittle-type failure of the main

structure of a passenger car, thereby providing protection of occupants

in the case of a crash.

Justification. NJ Transit requests a waiver from this requirement

because the SNJLRT vehicle will be designed to attain a sufficient

level of safety in the SNJLRT operating environment. The strict

temporal separation of the SNJLRT and Conrail services virtually

eliminates the risk of a collision between a SNJLRT vehicle and a

Conrail train, obviating the need for SNJLRT equipment to meet

conventional railroad car structural standards. Instead, the SNJLRT

vehicles are designed to withstand collisions with other light rail

vehicles, motor vehicles and similar objects. Relevant aspects of these

design standards are described below.

As noted above, the SNJLRT collision avoidance system is at the

heart of the SNJLRT safety design. Marked by complementary elements

such as operating rules and procedures, train control technology and

the SNJLRT signal system, the collision avoidance system will

significantly reduce the likelihood of collisions involving SNJLRT

vehicles. All signals capable of displaying ``stop'' aspect will

incorporate a trip-stop which will initiate a penalty brake application

if a SNJLRT vehicle passes a ``stop'' signal aspect. Moreover, the

SNJLRT vehicle's rapid deceleration design features will work to

further reduce the prospect of collisions and to significantly reduce

the closing speed, and accordingly, the seriousness of collisions that

do occur.

Above and beyond the crash avoidance features of the SNJLRT System,

the SNJLRT vehicles are designed to prevent sudden, brittle-type

failure of the main structure of a passenger car. The vehicle design

accommodates the actual progression of a failure induced by a sudden

collision phenomenon; from the elastic limit, through the plastic

limit, to a brittle failure. NJ Transit requires the SNJLRT vehicles to

be manufactured to comply with the standards as summarized below:

1. The passenger compartment will be capable of sustaining, without

any permanent deformation, at least 1.5 AWO longitudinal loads

(approximately 171,000 pounds) applied uniformly at the ends of the

passenger compartment, with a uniformly distributed AW4 vertical load

(approximately 165,375 pounds).

2. With the vehicle uniformly loaded to AW4, the end sill structure

will be capable of: sustaining loads up to the peak collapse load of

the crush zone without permanent deformation; sustaining the reaction

loads generated from the loads specified for collision posts, corner

posts and anti-climbers without permanent deformation; and

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distributing the collision loads incurred during scenarios specified

for crashworthiness, such that the collapse of the energy absorption

elements in the crush zones is the primary failure mode.

3. Vehicles will be capable of withstanding collisions with other

SNJLRT vehicles, motor vehicles, or overtravel buffers without

unnecessary risk of injury to passengers or excessive damage to SNJLRT

cars and/or track equipment. In a collision, no passenger compartment

shell will rupture or suffer any opening through which passengers'

limbs may protrude; no compartments within the engine compartment will

become dislodged and penetrate into the passenger compartment; high

voltage devices and associated connecting cables will remain contained

and will not create electrical shock hazards to personnel; and

electrical and diesel systems will not create a fire hazard.

To achieve the objective of crashworthiness, a crash energy

management approach was used as the basis of the SNJLRT vehicle

structural design. Further, as it is expected that during peak hours

that some passengers will stand, it was deemed important to minimize

the deceleration of passengers in the event of a frontal collision. In

a collision between a SNJLRT vehicle moving at speed V and a stationary

SNJLRT vehicle (i) both consists on level tangent track and unbraked,

(ii) couplers fully engaged, (iii) either SNJLRT vehicle either one or

two vehicles (i.e. the normal consist for comprising cars normally used

in revenue service), and (iv) any SNJLRT vehicle having a weight of AWO

(114,600 pounds):

Velocity Crash Energy Management

------------------------------------------------------------------------

V5...................... No damage to any SNJLRT car or

equipment, and the maximum

longitudinal acceleration measured

in any passenger compartment will

not exceed l.0g.

515................... Damage confirmed to the expendable

energy absorption devices and

sacrificial structural members at

the ends of the SNJLRT cars, which

will be repairable. The primary

structure enclosing the passenger

compartment(s) will remain intact,

with no permanent deformation of

any of its members. The maximum

longitudinal acceleration measured

in any passenger compartment will

not exceed 2g.

------------------------------------------------------------------------

In addition to the above, the SNJLRT cars have an aggressive

emergency deceleration rate of an average of 4.5 mph/sec through all

entry speeds. In an impending collision scenario this emergency brake

rate capability has the potential to reduce speeds prior to impact.

Section 238.205(a)--Anti-climbing Mechanism

Section 238.205(a) requires locomotives (as defined in Sec. 238.5)

to have forward and rear end anti-climbing mechanisms capable of

resisting an upward or downward vertical force of 200,000 pounds

without failure. These requirements are intended to prevent override or

telescoping of one passenger train unit into another in the event of

high compressive forces-caused by a derailment or collision.

Justification. NJ Transit requests a waiver of this requirement

because the SNJLRT vehicle will be designed so that: with only two ribs

of the anticlimbing mechanism engaged, and a vertical load of + 40,000

pounds combined with a longitudinal compressive load of AWO applied at

the carbody centerline, there will be no permanent deformation of the

carbody structure. In addition, crush elements within the couplers are

able to absorb a certain amount of energy in recoverable energy

absorption elements. When this occurs, the coupler moves back until the

anti-climbers of the colliding vehicles touch and the loads are taken

by the carbodies directly. Anti-climbers are fitted to the front end of

the cars to avoid telescoping.

While individual structural elements will not conform to the

requirement of Sec. 238.205(a), the assembled carbody uses ``crush

zones'' and other techniques to protect passengers in the event of

collisions. Specifically the SNJLRT vehicle is designed using advanced

computer methods to incorporate modern energy absorbing and dissipation

methods to dissipate energy and transfer loads and protect the

passenger compartment. The anti-climbers and energy absorption

mechanisms are designed to limit the potential for override and

underride and prevent telescoping. The SNJLRT vehicle design will

achieve the uniformity of end structure deformation essential to this

objective. Moreover, because the strict temporal separation of the

SNJLRT and Conrail services virtually eliminates the risk of SNJLRT

vehicle/Conrail train collisions, there is no need for the SNJLRT

vehicles to meet the more stringent requirements applicable to

conventional railroad equipment.

Section 238.207--Link Between Coupling Mechanism and Car Body

Section 238.207 requires the link between the car coupling

mechanism and the car body to be designed to resist a vertical downward

thrust from the coupler shank of 100,000 pounds for any normal

horizontal position of the coupler, without permanent deformation. The

purpose of this requirement is to avoid a premature failure of the

draft system so that the anticlimbing mechanism will have an

opportunity to engage.

Justification. NJ Transit requests a waiver from this requirement

because the SNJLRT vehicle has its own design features to accomplish

the purpose of the requirement. As noted above, the strict temporal

separation of the SNJLRT and Conrail services virtually eliminates the

risk of a collision between a SNJLRT vehicle and a Conrail train,

obviating the need for SNJLRT equipment to meet conventional railroad

car structural standards. Instead, the SNJLRT vehicles are designed to

withstand collisions with other light rail vehicles, motor vehicles and

similar objects. Relevant aspects of these design standards are

described below.

The SNJLRT vehicle will be designed so that the carbody structure

supporting the coupler will sustain, without permanent deformation, a

load that is equal to 110 percent of the coupler release load (if

applicable) or failure load applied at the coupler brackets, with a

uniformly distributed AW4 (165,375 pounds) vertical load. In addition,

the method of attaching the coupler to the coupler anchor bracket(s)

will allow the coupler to become fully released from the coupler anchor

bracket(s) once the coupler has absorbed its maximum design energy. The

coupler will be contained and prevented from coming in contact with the

track or from protruding into the passenger compartment. The coupler

and draft gear will withstand an operating consist with an AW3 (154,350

pounds) passenger load, pushing or pulling an unpowered consist with an

AW3 passenger load, over all grades and curves on SNJLRT Line, without

damage to the coupler.

[[Page 46002]]

The intent of the SNJLRT vehicle design is to prevent the coupler

shank from contributing to potential damage during a frontal collision.

The approach taken is to release the coupler from mechanical connection

to the carbody once it has absorbed its maximum design energy. When

this occurs the coupler assembly is separated from the coupler

anchorage on the car structure. The coupler is retained to prevent it

from coming into contact with the track or from protruding into the

passenger compartment. This feature is provided to reduce the risk of

derailment and penetration of the occupied space.

Section 238.209--Forward-Facing End Structure of Locomotives

Section 238.209 requires the skin of the forward-facing end of each

locomotive to be: equivalent to a \1/2\ inch steel plate with a 25,000

pounds per square inch yield strength; designed to inhibit the entry of

fluids into the occupied cab area of the locomotive; and affixed to the

collision posts or other main vertical structural members so as to add

to the strength of the end structure. These requirements are intended

to provide protection to persons in the occupied area of the locomotive

cab.

Justification. NJ Transit requests a waiver of the requirements in

this section because the SNJLRT vehicle will be designed to attain a

sufficient level of safety in the SNJLRT operating environment. As

noted above, the strict temporal separation of the SNJLRT and Conrail

services virtually eliminates the risk of a collision between a SNJLRT

vehicle and a Conrail train, obviating the need for SNJLRT equipment to

meet conventional railroad car structural standards. Instead, the

SNJLRT vehicles are designed to withstand collisions with other light

rail vehicles, motor vehicles, and similar objects. Relevant aspects of

these design standards are described below.

As noted above, the SNJLRT collision avoidance system is at the

heart of the SNJLRT safety design. Marked by complementary elements

such as operating rules and procedures, train control technology, and

the SNJLRT signal system, the collision avoidance system will

significantly reduce the likelihood of collisions involving SNJLRT

vehicles. Moreover, the SNJLRT vehicle's rapid deceleration design

features have the potential to mitigate the prospect of collisions and

to significantly reduce the closing speed, and accordingly, the

seriousness of collisions that may occur.

In addition, the SNJLRT system provides improved grade crossing

protection for the operator, passenger and vehicle through the use of

the crossing warning indicators which alert the operator to the gate

function and status. These indicators are comprised of lunar white

aspects, visible to the vehicle operator from at least a normal service

braking distance from the crossing. A flashing indication shall be

given at any time when the gates are operating and between fully down

and up positions. When the gates are fully down the indication shall be

steady. The operator can respond accordingly if a malfunction is

observed.

With respect to the specific design of the forward-facing end

structure, the SNJLRT vehicle is similar to a push-pull cab

configuration. The operator's cab floor height is 44'' and the vehicle

provides 171,000 pounds of buff strength.

Section 238.211--Collision Posts

Section 238.211 requires locomotives to have two full-height

collision posts at each end where coupling and uncoupling are expected.

Each collision post must have an ultimate longitudinal shear strength

of not less than 500,000 pounds at a point even with the top of the

underframe member to which it is attached and a longitudinal shear

strength of not less than 200,000 pounds exerted at 30 inches above the

joint of the post of the underframe. Alternatively, cars may be

constructed with an end structure that can withstand the sum of forces

that each collision post is required to withstand. This requirement is

intended to provide for protection against crushing of occupied areas

of passenger cars in the event of a collision or derailment.

Justification. NJ Transit requests a waiver of this requirement

because the SNJLRT vehicle will have collision posts, or a structural

equivalent, protecting at least the area between the underframe and the

bottom of the windshield. NJ Transit believes the SNJLRT vehicle design

will provide an adequate measure of safety. The strict temporal

separation of the SNJLRT and Conrail services virtually eliminates the

risk of a collision between a SNJLRT vehicle and a Contrail train,

obviating the need for SNJLRT equipment to meet conventional railroad

car structural standards. Instead, the SNJLRT vehicles are designed to

withstand collisions with other light rail vehicles, motor vehicles and

similar objects. Relevant aspects of these design standards are

described below.

As noted above, the SNJLRT collision avoidance system is at the

heart of the SNJLRT safety design. Marked by complementary elements

such as operating rules and procedures, train control technology, and

the SNJLRT signal system, the collision avoidance system will

significantly reduce the likelihood of collisions involving SNJLRT

vehicles. Moreover, the SNJLRT vehicle's rapid deceleration design

features will work to further reduce the prospect of collisions and to

significantly reduce the closing speed, and accordingly, the

seriousness of collisions that do occur.

In order to preclude sudden catastrophic failure or telescoping of

SNJLRT cars, all connections which attach collision posts, corner posts

and structural shelf to each other and/or the underframe structure and

roof structure, will be made in such a manner to develop the full

strength of the load bearing members in shear. The ultimate shear

strength of the collision posts will be not less than a compression

load of AWO (114,660 lbs) applied at the top of the underframe, and at

any angle up to 15 deg. from the longitudinal axis. A

compression load of 0.5 AWO (57,330 lbs) similarly applied 15 inches

above the top of the underframe will cause no yielding of the collision

posts. MI underfloor, roof mounted and engine compartment equipment

weighing more than 200 pounds will be designed to withstand not less

than 5.0 g in the longitudinal direction, 2.0 g in the lateral

direction, and 3.0 g in the vertical direction. These loads applied

separately will not result in stresses that exceed 90 percent of the

yield or buckling strength of the material.

These design requirements provide for the same type of protection

of the occupant space as the FRA collision posts requirements, but do

so in a way consistent with the design of the SNJLRT vehicle. As noted

elsewhere herein, the SNJLRT vehicle is designed using advanced

computer methods to incorporate modern energy absorbing and dissipation

methods as part of an overall protection system designed to dissipate

energy and transfer loads from impacts to protect the passenger

compartment. As part of this system, the SNJLRT collision posts provide

protection for the occupied volume of the vehicle shell during a

collision. Thus, the SNJLRT vehicle effectively isolates passengers and

crew from the hazards of penetration.

NJ Transit also notes that a portion of the SNJLRT system alignment

consists of street running. To operate safely in this environment the

operator requires good visibility to monitor road and pedestrian

traffic around the vehicle. Conventional collision post designs may

result in visual obstructions for the operator. This improved

visibility is

[[Page 46003]]

also beneficial when operating on the mainline railroad portion of the

route.

Section 238.213--Corner Posts

Section 238.213 requires two full-height corner posts at the end of

each vehicle capable of resisting, without failure, a load of 150,000

pounds at the point of attachment to the underframe and a load of

20,000 pounds at the point of attachment to the roof structure. Each

corner post must be able to resist a horizontal load of 30,000 pounds

applied 18 inches above the top of the floor without permanent

deformation. These requirements serve to provide protection to occupant

compartments from side-swipe type collisions.

Justification. NJ Transit requests a waiver of this requirement

because the SNJLRT vehicle will be designed to attain a sufficient

level of safety in the SNJLRT operating environment. As noted above,

the strict temporal separation of the SNJLRT and Conrail services

virtually eliminates the risk of a collision between a SNJLRT vehicle

and a Contrail train, obviating the need for SNJLRT equipment to meet

conventional railroad car structural standards. Instead, the SNJLRT

vehicles are designed to withstand collisions with other light rail

vehicles, motor vehicles, and similar objects. Relevant aspects of