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
Roelof van Ark
Chief Executive Officer
California High-Speed Rail Authority
770 LStreet, Suite 800
Sacramento, CA 95814
June 14, 2011
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
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
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
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
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
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
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.
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
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,
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
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,
? 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
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
? 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
? PTC technology and spectrum should be interoperable between jurisdictions and.
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.