Electronic Comment Filing System

ECFS Filing Proceeding: 11-79
Name of Filer: California High-Speed Rail Authority
View Filing:
Comments of the CHSRA (19)
Type of Filing: COMMENT
Exparte Presentation: NO
Date Received: 6/14/11
Date Posted: 6/15/11 10:42 AM
File Number: WT Docket No. 11-79
Address: 770 L Street Suite 800 Sacramento, CA 95814

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Spectrum Needs for the Implementation of the Positive Train Control Provisions of the Rail Safety Improvement Act of 2008 WT Docket No. 11-79 COMMENTS OF CALIFORNIA HIGH-SPEED RAIL AUTHORITY Re Roelof van Ark Chief Executive Officer California High-Speed Rail Authority 770 LStreet, Suite 800 Sacramento, CA 95814 rvanark@hsr.ca.gov (916) 384-1488 June 14, 2011 Executive Summary The California High-Speed Rail Authority (CHSRA) commends the Commission for its efforts to seek information in advance to anticipate and manage spectrum availability issues potentially impacting the implementation of Positive Train Control (PTC) technology. The Notice of Inquiry (NOI), docket WT Docket No. 11-79, requests information about spectrum issues related to the implementation of PTC pursuant to the Rail Safety Improvement Act of 2008 (RSIA) and corresponding Federal Railroad Administration (FRA) regulations. The CHSRA is grateful for the opportunity to provide the Commission with PTC requirements unique to the high-speed rail environment, information on high-speed applicable PTC technologies, spectrum requirements and recommendations. The CHSRA is a State of California agency responsible for commissioning the California High Speed Train Project (CHSTP) to meet the state's growing public transportation needs. This project involves the design and construction of an 800 mile high-speed rail system that will connect California's major metropolitan centers with new dedicated tracks and infrastructure. While normal train operations will occur at 220mph, the infrastructure and systems will be designed to support train travel at 250 mph, where feasible. Travel time between San Francisco and Los Angeles is mandated to be 2 hours and 40 minutes by California's Safe, Reliable High Speed Passenger Train Bond Act (Proposition lA). Extensive research and investigation by the CHSRA has shown that the European Rail Traffic Management System (ERTMS) composed of the European Train Control System (ETCS) Level 2 and the Global System for Mobile Communications - Railway (GSM-R) is the only fully compliant and service proven system that can deliver PTC that meets the performance levels for CHSTP. ERTMS is a broadly proven, standardized, multi-supplier PTC technology being implemented globally for conventional and high-speed rail operations. Originally developed in Europe for the purposes of ensuring an interoperable train control across the member states of the European Economic Community, ERTMS has become the world train control standard adopted by nations including China, South Korea, and India. CHSRA has determined that alternative PTC technologies are not fully compliant with the project requirements and / or present excessive development and implementation risk. In the US, the rail industry is focused on developing PTC technology designed for speeds below 110 mph and the Commission has allocated 220 MHz spectrum to support this technology. However, the 220 MHz PTC systems under development will not support the performance levels envisioned for the CHSTP and it is unlikely that this technology can be developed and demonstrated to operate safely at 250 mph within the CHSTP implementation schedule. The challenge to the CHSRA in implementing ETCS Level 2 with GSM-R is the lack of available spectrum for GSM-R. To conform to the RSIA and corresponding FRA regulations, the CHSRA requires PTC technology developed for and proven in high-speed operation. Therefore the CHSRA respectfully recommends that the Commission consider reserving a band (or bands) to be used exclusively by railroads, particularly high-speed railroads including the CHSRA, for the implementation ETeS Level 2 with GSM-R for PTe. The eHSRA recommends this band (or bands) be coordinated by a single/ independent entity. This proposed policy would dramatically aid the eHSRA in cost-effectively achieving its objectives/ and would aid other railroads developing high-speed rail systems that will likely encounter difficulties from 220 MHz PTe limitations/ development delays/ hardware and software monopoly issues/ licensing fees and spectrum availability by providing a globat proven/ open/ standardized/ multi-vendor ERTMS marketplace for a compliant high-speed train PTe solution. Federal support for the introduction of standards developed worldwide will allow for the smooth introduction of highly reliable and safe high speed systems in this country and enable US systems suppliers future successful participation in the global business of high speed rail based on global standards. Table of Contents 1 Introduction 5 2 Positive Train Control for California High-Speed Rail.. 6 2.1 ERTMS/ETCS Level 2 with GSM-R 7 2.2 Other PTC Technologies Investigated for California High-Speed Rail 8 2.2.1 Shinkansen DS-ATC 8 2.2.2 TVM-430 9 2.2.3 Positive Train Control at 220MHz 9 2.2.4 ERTMS/ETCS Levell : 10 2.3 Spectrum Issues Impacting PTC for California High-Speed Rail... l0 2.4 Summary of Recommendations 18 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Spectrum Needs for the Implementation of the Positive Train Control Provisions of the Rail Safety Improvement Act of 2008 WT Docket No. 11-79 COMMENTS OF CALIFORNIA HIGH-SPEED RAIL AUTHORITY 1 Introduction The California High-Speed Rail Authority (CHSRA) respectfully submits these comments in response to the FCC's above-captioned Notice of Inquiry (NOlL in which the Commission is investigating spectrum issues related to the implementation of Positive Train Control (PTC) pursuant to the Rail Safety Improvement Act of 2008 (RSIA) and corresponding Federal Railroad Administration (FRA) regulations. The CHSRA commends and strongly supports the Commission in its efforts to address spectrum issues related to the implementation of PTC for all rail operators. The CHSRA is commissioning the California High-Speed Train Project (CHSTP), an 800 mile high speed rail system that will connect California's major metropolitan centers with new dedicated tracks, infrastructure and trains. While normal train operations will occur at 220mph, the project will be designed to support train travel at 250 mph. Travel time between San Francisco and Los Angeles is mandated to be 2 hours and 40 minutes by California's Safe, Reliable High Speed Passenger Train Bond Act (Proposition 1A). The CHSRA has the mandate to provide safe, high-speed train service and has developed project and technical requirements to deliver the CHSTP with low risk, low cost and a high and compliant level of safety. A key commitment of the CHSRA design approach is to use service proven technologies and components in all critical applications. This entails specification and selection for mission-critical and safety-critical systems of equipment already successfully proven in high-speed rail service at or near the intended operating speeds of the CHSTP. Service-proven technology is essential in order to be compliant with the Code of Federal Regulations (49CFR Part 236.1007.c.1) which requires that the CHSRA establish that the PTC system deployed for the CHSTP: If ??? Will be operated at a level of safety comparable to that achieved over the 5 year period prior to the submission of the PTCSP [PTC Safety Plan] by other train control systems that perform PTC functions required by this subpart, and which have been utilized on high-speed rail systems with similar technical and operational characteristics in the United States or in foreign service, provided that the use of foreign service data must be approved by the Associate Administrator before submittal of the PTesp. /I A major task in bringing high-speed rail technology to the US is establishing engineering standards and specifications which ensure safe and reliable operation of the trains at speeds significantly higher than those currently in service in this country. To minimize project risk, a key commitment of the CHSRA design approach is to use service-proven technologies and components in all critical applications. This entails specification and selection for mission critical and safety-critical systems of equipment already successfully proven in high-speed rail service in Europe and Asia. This approach is also in compliance with the Code of Federal Regulations section noted in the previous paragraph. The project criteria require that all technologies and implementations proposed by design bidders be proven in passenger service, under similar conditions, at or near CHSTP speeds, in other rail systems for a minimum of five years. Furthermore, these requirements will make proving safe operation and securing safety approval from the Federal Railroad Administration (FRA) and other US regulatory bodies more straightforward compared to deploying an unknown and unproven technology. A mandated CHSTP objective is to be at least revenue neutral; operations and maintenance costs must be balanced by fare and other revenue. Consistent with this objective, the CHSRA requires multiple supplier sources for procurement, bidding, and supply of critical systems including PTe. Interoperable, interchangeable, open-standard and multi-vendor solutions are required and will provide the CHSRA with several sources of supply for extensions, upgrades, and maintenance spare parts in the present and future, controlling risk and cost. The most widely available technology that fully complies with the CHSRA project and technical requirements is the European Rail Traffic Management System (ERTMS). ERTMS is composed of two subsystems: the European Train Control System (ETCS) Level 2 and the Global System for Mobile Communications - Railway (GSM-R). ETCS provides PTC and GSM-R provides the communications path for ETCS PTC, voice and other data communications. ERTMS is broadly service-proven, standardized, subject to fully-documented regulatory assessment and approval, and developed and sold by multiple international vendors. Its functions, characteristics, performance and system assurance fully conform to CHSTP PTC and radio communications requirements. Originally developed in Europe for the purposes of ensuring an interoperable train control across the member states of the European Economic Community, ERTMS has become the world train control standard adopted by nations including China, South Korea, and India. 2 Positive Train Control for California High-Speed Rail PTC is a safety-critical train control function mandated to prevent train-to-train collisions, over speed derailments, incursions into established work zones, and the movement of trains through switches left in the wrong position. Because of the speed of train travel, the CHSTP PTC requirements and suitable technologies are more exacting than PTC needs for conventional passenger and freight rail service. PTC regulatory requirements for CHSTP are also more restrictive than those for freight and commuter rail services that operate at speeds less than 125 mph. Recalling that per 49 C.F.R. § 236.1007, the CHSRA is required to establish that the PTC technology deployed is comparable in safety to iI ...other train control systems that perform PTC functions required by this subpart, and which have been utilized on high-speed rail systems with similar technical and operational characteristics in the United States or in foreign service...", the CHSRA is pursuing existing, service-proven technology to minimize risk to certification as well as implementation. The CHSRA has identified and investigated multiple candidate PTC technologies which fully or partially meet the project and technical requirements. The following sections present the PTC technologies investigated by the CHSRA. 2.1 ERTMS/ETCS Level 2 with GSM-R ETCS Level 2 with GSM-R is the primary candidate for PTC and radio communications for CHSTP. It is the sole PTC candidate that fulfills all CHSTP requirements. The International Union of Railways (Ule) began developing ERTMS specifications in the 1990s to create a safe, reliable, efficient and interoperable rail traffic management system for high speed and conventional rail networks within the European Union. The ERTMS specifications describe a PTC system which allows trains to travel across different railroad networks without trains carrying multiple train control and voice radio systems or changing locomotive or trainset at the network border. ERTMS is now a widely proven technology: ? Level 2 is in service across Europe and China on high-speed lines. ? Level 2 system is being built in Saudi Arabia for high-speed lines. ? Level 2 system is being planned for high-speed operation in Argentina ? Level 2 systems are under construction in Algeria, Australia, and Turkey for conventional speed lines. ERTMS Level 1 is deployed across Europe, China, South Korea, India, Australia, and Mexico. With the addition of GSM-R, Levell systems are readily upgradable to Level 2. The PTC component of ERTMS, ETCS, defines three application levels: Levell, using predominantly transponder and inductive loop technology for track-to-train communications; Level 2, using continuous radio communications between the train and the radio block center (RBe) at the wayside; and Level 3, with train integrity controlled on-board and continuous radio communications providing moving block technology (Level 3 is in a conceptual phase and is not yet available as a proven product). ETCS Level 2 does not require wayside signals. The train's authorization to proceed on the track, or Movement Authority, is communicated from a wayside controller to the onboard train control unit using GSM-R. A continuous wireless stream of Movement Authority data informs the train engineer and the onboard PTC unit of the speed limit, safe distance to travel, and of line-specific data on the route ahead, allowing the train to operate at a safe, efficient speed while maintaining a safe braking distance factor. Compared to ETCS Level 1 which must use wayside signals, ETCS Level 2 can significantly increase line capacity by optimizing block sections, enabling higher operational speeds, and controlling to closer headways. Higher line capacity is a critical economic benefit for a rail line. ETCS Level 2 greatly reduces maintenance costs because it does not need wayside signals. Furthermore, Swiss railway authorities reported a significant decrease in average delay per train after introducing ETCS Level 2 system on certain lines. ETCS Level 2 with GSM-R, designed for operations up to 310 mph, is becoming the dominant global de-facto train control and communications standard for high-speed rail. It has been verified as a reliable technology, tested and proven in revenue-service at maximum speeds of about 220 mph. GSM-R, the wireless component supporting ETCS Level 2, is a multi-function, integrated radio system which delivers safety-critical PTC data, train-to-wayside voice communication, multiple voice channels for railroad personnel and passenger information, and other digital data. GSM-R is based on GSM and EIRENE (European Integrated Railway Radio Enhanced Network) specifications, developed by the UIC, and now in the responsibility of the European Railway Agency (ERA). GSM-R provides secure voice and data communication between railway operational staff, including train engineers, dispatchers, yard staff, and station personnel. It includes features specifically for high-speed rail operations, such as voice group call services (VGCS), voice broadcast services (VBS), functional addressing, location-based connections, and railway emergency call services. ETCS Level 2 with GSM-R is standardized, subject to fully documented regulatory assessment and approval, developed and sold by multiple vendors, and proven for more than five years at CHSTP speeds as a safety-critical PTC system providing reliable passenger train service. ETCS Level 2 with GSM-R is the preferred solution for CHSTP train control and radio. 2.2 Other PTC Technologies Investigatedfor California High-Speed Rail If the CHSRA cannot implement ETCS Level 2 with GSM-R, it must provide PTC with a different technology. The available alternative technologies and products do not fully comply or are completely non-compliant with the CHSTP project and technical requirements. These technologies include the Shinkansen OS-ATC, TVM-430, PTC at 220MHz and ETCS Levell. If the CHSRA selects one of these alternative PTC systems, CHSRA will still need spectrum for voice and other data communications. 2.2.1 Shinkansen OS-ATC The Japanese Shinkansen OS-ATC train control operates up to approximately 200 mph and has been proven in operation for more than five years. OS-ATC does not require spectrum. However, OS-ATC does not comply with key CHSTP project and technical requirements because it is a proprietary system provided by a single supplier. The key concern is that this entails significant risk for system procurement, extensions, upgrades, and maintenance parts. Furthermore, OS-ATC has not been subject to a documented regulatory approval process compatible with US or EuroNorm (EN) practices. The CHSRA has not ruled out OS-ATC for CHSTP PTe. If CHSRA had no choice other than to waive the non-compliant project requirements and if OS-ATC were adapted to 220 mph operation, the CHSTP would still require dedicated spectrum to support reliable voice and other data comm.unications at the planned maximum operating speed of 250 mph. 2.2.2 TVM-430 Transmission Voie-Machine (TVM, or in English, track-to-train transmission) is a form of in-cab signaling originally and predominantly deployed in France and used on the Lignes a Grande Vitesse (LGV), high-speed railway lines. TVM-430 uses encoded track circuits to transmit PTC data to trains within blocks and does not require radio spectrum. TVM-430 transmits information including the state of signaling blocks further ahead and gradient profiles ahead. It is proven at speeds up to 250 mph. The most recent French TGV line is equipped with both ETCS Level 2 signaling and TVM-430 signaling. However, the CHSRA eliminated TVM-430 from consideration. It is effectively obsolete since French authorities have decided that new French lines and signaling upgrades will use ERTMS. 2.2.3 Positive Train Control at 220MHz Design for the emerging PTC technology as per the Railway Safety Improvement Act of 2008 at 220MHz is focused on delivering PTC at train speeds below 110 mph using a dedicated radio system. This technology is currently in development and it is uncertain whether 220MHz PTC systems could be adapted to safely operate at 250 mph, representing significant risk to implementing CHSTP using the technology. Additionally, Doppler shift, fading, including multipath fading and other radio phenomenon which disturb system performance are emphasized in the high-speed rail environment.. Solutions to mitigate these radio impacts must be integrated early into design of the system, otherwise this represents intolerable risk. Furthermore, the freight railroads have already stated that the available 220 MHz spectrum is insufficient to support existing PTC needs in dense areas such as the Los Angeles basin, through which CHSTP will also operate. If 220 MHz capacity is inadequate for existing freight railroads, it cannot support the added demand of CHSTP service. Wabtec Railway Electronics and a consortium of the Class 1 freight railroads have been developing the Wabtec Electronic Train Management System (ETMS) to fill the nationwide interoperable PTC needs for US freight railroads. ETMS PTC uses wireless digital packet communication between locomotives, waysides and dispatch to deliver digital track authorities, track database updates, consist information from dispatch, and real-time wayside status to the locomotive. Wabtec is presently developing interoperability enhancements and a vital (safety critical) version of ETMS. MeteorComm LLC, a radio developer owned by Class 1 freight railroads, is developing the radios. However, the radio development schedule has slipped significantly since its inception and continues to be delayed. The PTC community was recently informed that using MeteorComm technologies will require users (including CHSRA) to pay licensing fees for hardware, software, and transmission rights, in a long-term, sole-supplier relationship for .procurement of the system, radio service, extensions, upgrades, and maintenance parts. The MeteorComm monopoly arrangement for 220 MHz PTC technology adds sourcing risk and additional cost to the CHSTP, and does not comply with the CHSTP technical or project requirements. If a 220M Hz PTC solution were eventually developed and demonstrated for safe and dependable for high-speed rail operations, and the five-year service-proven requirement and sole source prohibition were waived, CHSTP would still need a voice and data radio solution, and spectrum. 2.2.4 ERTMS/ETCS Levell ETCS Levell is a potentially viable candidate technology for CHSTP PTe. ETCS Levell has been implemented in China at speeds close to the CHSTP 220 mph target and in Spain at speeds up to 185 mph. ETCS Levell does not require radio spectrum to deliver PTC functionality. As mentioned earlier in this response, ETCS Levell was designed as an enforcement overlay to conventional wayside signals. However, in order for it to approach the performance capabilities of Level 2, significant amounts of additional equipment are required to improve its intermittent communications capabilities. Transponders connected via copper cable to the wayside sub-system are required for Levell, wherein Level 2 no cabling is necessary to the transponders, in many locations additional significant number of infill transponders and/or inductive loops are also required particularly in the approach to wayside signals or other common train stopping points to enable advancement of movement authorities to be transmitted to a train which has had to slow down or stop due to a train ahead or a conflicting route having cleared. Until recent implementation of systemwide speed reductions, Level 1 appeared to be operating at its functional limits on a single line in China at speeds close to 220 . mph although recently constructed Chinese high-speed lines have all been equipped with their derivative of ETCS Level 2 which also uses GSM-R and spectrum. Compared to ETCS Level 2, ETCS Levell reduces the CHSTP capability to maximize train and system performance. ETCS Level 1 has not been deployed at 220 mph on a line with dense service similar to the CHSTP. However, if the CHSRA accepts and adapts ETCS Levell for CHSTP, a voice and data radio solution, and spectrum, would still be needed. 2.3 Spectrum Issues Impacting PTCfor California High-Speed Rail The following paragraphs respond to the Commission's specific inquiries within the FCC NOI. liThe Bureau seeks comment from stakeholders regarding the frequency bands and amount of spectrum needed to successfully implement PTe." ETCS Level 2 with GSM-R is a widely available and viable low-risk path for implementing the PTC, voice and data radio service for CHSTP, if the CHSRA can acquire suitable spectrum for its use. In Europe and much of the world, GSM-R is allocated 2 x 4 MHz blocks (876 MHz - 880 MHz for uplink and 921 MHz - 925 MHz for downlink) with a channel bandwidth of 200 kHz. Using this spectrum (referred to as "native" herein) or any possible pair of 4 MHz blocks in GSM900 bands (876 MHz - 880 MHz for uplink and 921 MHz - 960 MHz for downlink) with minimum duplex spacing of 45 MHz is the lowest-risk path for deploying a GSM-R system for CHSTP, as the worldwide GSM-R equipment marketplace richly supports these frequencies. Currently, ETCS data communication relies on Circuit Switched Data (CSD) connections over GSM-R. This requires one time slot out of 8 per frequency carrier to be dedicated for each train within each cell that is included in a train's Movement Authority. The ERA, UIC and other stakeholders currently are working on solutions to enhance both capacity and quality of services for GSM-R. Among other enhancements, General Package Radio Service (GPRS) for ETCS data communication is under evaluation and testing. GPRS is already used in service for non-ETCS, non-safety critical data transmissions. GPRS utilization for ETCS will yield higher spectral efficiency. It is expected that GPRS for high-speed, critical train operation incorporated into the next update to ERTMS specifications which are planned to be issued in 2012. In this arrangement, ETCS Level 2 PTC data would be transmitted via GPRS allowing higher spectral efficiency and potentially less spectrum usage. A basic implementation of GSM-R for CHSTP would require 2 x 4 MHz blocks in bands in which GSM radios operate or can be adapted to operate. However, recognizing that spectrum is a limited natural resource which must be conserved, the CHSRA has evaluated minimum useful bandwidths. Using CHSTP operational estimates, the CHSRA has performed high-level, theoretical calculations to determine the minimum spectrum needed to deploy ETCS Level 2 with GSM-R in the native GSM-R frequency spectrum. The calculations show that the spectrum needs are not uniform along the line. However, the conclusion based on the results and the inputs from various existing systems in operation is that the general requirement of 2 x 4 MHz shall be considered the minimum amount of spectrum necessary to deploy an ETCS Level 2 with GSM-R system for CHSTP. The 4 MHz GSM-R uplink and downlink bands must be separated to avoid interference. A proven, non-interfering distance in the native GSM-R frequency spectrum for paired uplink and downlink frequency carriers is 45 MHz. "...we seek comment on geographic areas where meeting the spectrum needs for PTe are likely to present the most challenges. II The dense urban areas of the San Francisco peninsula and the Los Angeles metropolitan area present the greatest challenges to spectrum acquisition, since there is more competition and many existing users of the spectrum suitable for GSM-R. Without Commission assistance, the CHSRA believes that acquiring spectrum in these metropolitan areas will be prohibitively expensive or impossible. The likely cost of spectrum acquisition in the California Central Valley is only marginally lower. "...we seek information regarding how the use of different frequencies and amounts of spectrum could affect the functionalities and components of a PTe system. /I The CHSRA met with leading vendors of ETCS and GSM-R and found that GSM-R hardware currently available in the marketplace is flexible in operating frequency. The more modern GSM-R base stations and mobile radio equipment can operate throughout standard GSM bands, including the GSM-R band and the DCS-1800 GSM band. However, several vendors expressed concern that Doppler shift for a mobile radio unit traveling at 250 mph is too great for a GSM-R radio system operating above 960 MHz, the upper limit of the GSM-R band. Existing GSM-R products operating in the DCS-1800 GSM band can achieve maximum speeds of 150 mph to 205 mph (depending on vendor) while maintaining required quality of service. Vendors specifically indicated that alternative GSM bands including 450 MHz and 700 MHz could be candidates for a GSM-R system for CHSTP. Based on these inputs, the CHSRA assumes that vendors can modify or build new radios to provide GSM-R service in almost any existing GSM band below 960 MHz for CHSTP speeds, with no impact on system functionality and minimal risk. While any modification to the standard GSM-R system used in Europe and elsewhere must be fully tested and proven, the CHSRA assumes a modification to another GSM band is relatively low-risk, since it has been executed successfully in other countries. However, any GSM-R system adaptation for frequencies outside the standardized GSM bands would require major product adjustments, development and testing which will raise the cost and bring new implementation risks. As mentioned above, acquiring spectrum, in particular in the GSM 900 and native GSM-R frequency bands in the metropolitan areas of California will be the greatest challenge in implementing a GSM-R system for the CHSRA. However, knOWing that the CHSTP train speeds in these metropolitan areas will be slightly lower than the maximum of 220 mph in rural areas, and assuming: ? DCS-1800 GSM band spectrum may be more likely to be available than GSM 900 or native GSM-R band spectrum in metropolitan areas; ? GSM 900 / native GSM-R spectrum may be more likely to be available in rural areas where train speeds are highest, and; ? 220 mph train speeds can be supported by spectrum below 960MHz and train speeds less than 220 mph can be supported by spectrum above 960 MHz; it may be feasible for the CHSRA to deploy a dual-mode GSM-R system using different frequency spectrum in different geographical areas to support CHSTP requirements with minimal risk to implementation. Among other challenges including spectrum availability, there would be regulatory challenges to deploying a GSM-R system in the US at other GSM bands. The 450 MHz band is used extensively by radio systems including Private and Public Land Mobile systems, and adequate spectrum is unlikely to be available for acquisition by CHSRA. Furthermore, this band is not channelized in 200 kHz channels required for a GSM-R deployment. GSM-R cannot be deployed at the 5 kHz channelized spectrum at 220 MHz and it is not economically feasible to migrate GSM-R to 220 MHz as it is not a standardized GSM band. The spectrum bandwidth allocated to a GSM-R system will determine its train-handling capacity and performance since the amount bandwidth determines the amount of PTC, voice and other data traffic that can be carried. According to a detailed CHSTP assessment, at least 2x4 MHz with a 45 MHz uplink and downlink spacing is needed for the PTC, voice and other data needed to sustain CHSTP operations. The effect of a major spectrum compromise in a GSM-R design will result in dropped calls and trains braking unnecessarily and in some cases coming to a stop. "We also seek input regarding how aspects of various rail operations affect the amount of spectrum or frequencies needed to successfully implement PTe. Such factors could include the speed of train operations, the number of track lines in a certain geographic area, the amount of rail traffic on track lines, the temporal separation of trains, and the hours of operation of commercial services on a track line." Because spectrum is a limited natural resource, the CHSRA performed theoretical capacity and bandwidth calculations reflecting the planned train operations and environment (including the factors that the Commission listed in the inquiry) to determine the minimum amount of spectrum required to support CHSTP rail operations. CHSRA capacity calculations considered the following factors: ? Cell size and maximum number of trains and users within a cell ? Speed of trains (affects hand-off time and coverage overlap) ? Mobile usage profile and number of mobiles ? Talk group plan for operations and maintenance personnel ? Radio site locations and network redundancy scheme ? ERTMS data radio quality of service requirements ? Typical and worst-case statistical distribution of demand for service from multiple users ? Signal propagation constraints developed from RF coverage simulations These factors determine the required GSM-R data bandwidth and therefore the amount of spectrum needed. liThe Bureau also seeks comment on the spectrum coverage area that will be needed by the railroad industry for PTe implementation. For examplel we seek input regarding the approximate amount of geography on either side of a track line where signal coverage is necessary to operate a PTe systeml recognizing that a freight or passenger rail would not require spectrum solutions outside a certain distance from a track line. II Since 1982, the Commission has assigned spectrum licenses based on the geographic area of coverage. These coverage area designations are aggregations of counties. This means of license demarcation is less than ideal for railroads because only a relatively small amount of the licensed geography needs radio coverage to support PTC and railroad operations. Because GSM-R system accommodates PTC, voice and other data communications, the CHSRA requires a lateral coverage width of 3.5 miles (1.75 miles on each side of the right-of-way) to cover the trains and also provide radio coverage for maintenance personnel who are approaching the right-of-way for maintenance or other functions. However, the CHSRA also envisions a scenario where it could operate with a narrow coverage area that only focused propagation within the right-of-way and did not provide significant lateral coverage. GSM-R general purpose and operational handheld terminals can be supplied as multi-mode (band) devices allowing them to work in GSM-R and commercial GSM cellular networks. For CHSTP, a roaming agreement between the GSM-R network operator and the adjacent commercial GSM network operators would provide coverage when away from the right-of-way coverage area. Commercial GSM operators' networks don't provide the EIRENE quality of service necessary for safety-critical PTC and railroad operations; however commercial GSM cellular service would only be used by the on-call (reserve) operational and maintenance personnel while out-of-coverage. "... the Bureau seeks comment regarding policy actions that would further facilitate the acquisition of spectrum by railroads subject to the RSIA for PTe implementation. II Considering the unique requirements for PTC for high-speed trains, the limited choices of proven technology to fulfill the PTC requirements, and the CHSRA's inability to compete in the auction market for spectrum against the commercial cellular carriers, the CHSRA is in a similar position to Public Safety entities before the Digital Television and Public Safety Act of 2005 created exclusive bands for Public Safety's use. like all railroads, the CHSRA will operate critical infrastructure and CHSRA requires a safety-critical radio system, and spectrum, to provide PTC, voice and other data communications. The CHSRA respectfully recommends that the Commission implement policies that would further facilitate CHSRA and other railroads acquisition of spectrum for PTC: ? Similar to the 700 MHz Public Safety bands, the Commission may consider identifying spectrum to be used exclusively by railroads (including high-speed railroads) to implement GSM-R for PTe. The CHSRA recommends this spectrum be coordinated by a single, independent entity and recommends that this spectrum be 2 x 4 MHz blocks in the GSM 900 band with minimum duplex spacing of 45 MHz, ideally in the native GSM-R bands: 876 MHz -880M Hz and 921MHz - 925MHz. This proposed policy would dramatically aid the CHSRA in cost-effectively achieving its objectives, and would aid other railroads stymied by 220 MHz PTC limitations, development delays, licensing fees, or spectrum availability by letting them use the global, proven, open, standardized, multi-vendor ERTMS marketplace for a PTC solution. ? The Commission may consider developing a new licensing plan or a frequency coordination process for railroads to acquire licenses for limited-width swaths of geography (covering only the right-of-way) for suitable bands. PTC communications for trains may share a relatively small sliver of geographical coverage area with an existing license holder with an appropriate technology or use. Even though trains are mobile, their paths of travel are known and fixed. The deterministic behavior of trains may be exploited by the Commission to devise creative solutions to spectrum issues. "We seek comment regarding whether it is possible for railroads or industry participants that already hold spectrum rights to facilitate PTC implementation for railroads, which are not currently FCC licensees or lessees, operating on the same track or in the same geographic area (e.g., urban area or FCC license area)." Because GSM-R is based on GSM technology, the spectrum sharing, frequency planning, interference mitigation and similar issues are well-known in the commercial cellular industry. The CHSRA believes that the worldwide deployment of GSM-R (and GSM) by multiple entities sharing the same spectrum proves that that this model can be recreated here in the US with high confidence of success for all railroads. "More generally, we request information regarding any testing that has been performed on PTC systems (utilizing various frequency bands and amounts of spectrum) in the United States or in other countries." ERTMS specification development started in the beginning of the 1990's in Europe. The European Union, through series of directives and technical specifications of interoperability mandated and enabled ERTMS system development across the major European railway corridors, designating frequency bands for railway purposes and mandating the system's adoption to the EU member countries accordingly. The first ETCS Level 2 with GSM-R implementations put into revenue service were the following: ? In 2004, in Switzerland on the Mattstetten Rothrist line (Olten - Berne), at a distance of 30 miles at initial speeds of 100 mph eventually reaching 124 mph ? In 2005, in Germany on the Berlin - Halle/Leipzig line, at a distance of 83 miles at speeds of 124 mph ? In 2005, in Italy on the first dedicated high-speed line between Rome and Napoli, at a distance of 124 miles at speeds of 186 mph ? In 2006, in Italy on the high-speed line Torino-Novara, at a distance of 56 miles at speeds of 186 mph ? In 2006, in Spain more than 400 miles of high-speed lines operating at speeds from 124 mph· to 186 mph and on the Almodovar del Rio line (west of Cordoba) Antequera/Santa Ana at speeds up to 220 mph On all of these projects, the ETCS Level 2 with GSM-R system passed through extensive testing in non-revenue operations and after initial implementation issues were addressed, have achieved outstanding safety and availability performance in revenue operation. For example, as reported on the UIC 6th World Congress on High Speed Rail held in 2008 in Amsterdam, the Italian high-speed railway system unavailability due to ETCS faults has been tested and confirmed to be less than 8 minutes per year. Since these initial deployments of ETCS Level 2 with GSM-R, hundreds of miles of new lines equipped with ERTMS have been contracted and put in operation every year, increasingly outside of Europe. ETCS Level 2 with GSM-R has been delivering PTC, voice and other data communications to conventional and high-speed railways in a growing list of countries. GSM-R has been deployed in the following bands: Country or Region Frequency Uplink Downlink Bandwidth Band Frequencies1 Frequencies2 (in MHz) (in MHZ) Europe R-GSM 876 -915 921- 960 2 x 4 MHz (and most other regions) (876 - 880)3 (921- 925)3 China E-GSM 880-915 925 - 960 2 x 4 MHz (885 - 889)3 (930 - 934)3 AustraliaS DCS-1800 1705 - 17854 1805 -18804 2 x 15 MHz Note 1: Link from the Mobile Station to the Base Transceiver Station Note 2: Link from the Base Transceiver Station to the Mobile Station Note 3: Frequency spectrum in which the GSM-R Base Transceiver Stations operate Note 4: This frequency band has been divided and auctioned in paired parcels each of 2x2.5 MHz with duplex spacing of 95 MHz. Railroads acquired six mostly non-grouped parcels which cover 2x15 MHz of this frequency band in which the GSM-R projects have been implemented. Note 5: Top speed is limited to 99 mph (160 km/h) and GSM-R carries voice traffic only. "Finally, the Bureau invites comment on any other pertinent issues regarding spectrum needs for successful PTe system deployment. II As the Commission considers spectrum needs for PTC deployment, the CHSRA respectfully highlights several points below: ? PTC technology and spectrum selection must be developed and selected in a systematic manner. All users' operational needs should be identified, quantified and then standardized. With these needs and ~equirements defined, technology can be developed and spectrum identified to meet those needs. ? Ideally, PTC technology should be built on open, non-proprietary systems using publically available standards, protocols, safety verification methodologies, and interfaces. Similarly, suitable spectrum must be accessible to users subject to any PTC mandate. ? PTC technology and spectrum should be interoperable between jurisdictions and. regions. 2.4 Summary ofRecommendations The CHSRA appreciates the opportunity to discuss the details of the CHSTP PTC investigation and implementation with the Commission. The CHSRA has the mandate to provide safe, dependable high-speed train service. It has developed project and technical requirements to deliver the CHSTP with low risk, low cost and a high and compliant level of safety and service. Because of the high-speed of operation and different regulatory requirements, the CHSTP has different PTC requirements and therefore a different suite of technologies and products adaptable to provide PTC functions than conventional railroads. Based on these requirements, the sole product that is fully compliant with all of the CHSRA project and technical requirements is the ERTMS consisting of ETCS Level 2 with GSM-R. ERTMS is broadly service-proven, standardized, subject to fully-documented regulatory assessment and approval and developed and sold by multiple, international vendors. Its functions, characteristics, performance and system assurance fully conform to CHSTP PTC and radio communications requirements. The sole obstacle to implementing ERTMS for CHSTP is the availability of spectrum. In summary, the CHSRA respectfully recommends that the FCC: 1. Investigates options for accommodating GSM-R functionality that will support an ERTMS Level 2 train control system, voice and other data communication between wayside and trains moving at up to 250 mph for CHSTP, other high-speed railroads and conventional railroads. As a result of the investigations and needs analysis, reserve spectrum (any possible pair of 4 MHz blocks in GSM 900 band with minimum duplex spacing of 45 MHz, ideally in the native GSM-R bands: 876 MHz -880MHz and 921MHz - 925MHz) to be allocated to and used exclusively by railroads (including high-speed railroads) to implement ETeS Level 2 with GSM-R for PTe. 2. Investigates and develops a new licensing plan or a frequency coordination process for railroads to acquire licenses for known, limited-width swaths of land (covering only the right-of-way) within other license holders' geographic areas in suitable bands. 3. Develops a systematic means of identifying spectrum to meet the needs and requirements of all end users, including high-speed and conventional railroads. Because it is to be used by all railroads subject to the PTe mandates, PTe technology and spectrum should be open, accessible, non-proprietary and interoperable.