Dharma Cloud Foundation

PO Box 1066                                Tel: 707 937-3001
Mendocino, CA 95460                 Fax: 707 937-3192

September 14, 2001

Sara Wan, Chair
California Coastal Commission
45 Fremont Avenue, Suite 2000
San Francisco, CA 94105-2219

Dear Sara:

I want to immediately resolve doubts that may have been left in Commissioners minds by Caltrans responses to my presentation of a picture of an actual, installed Wyoming Rail.

First, there is no significant visual difference between the Wyoming TL-4 rail and the TL-3 rail that I showed.  Both have two horizontal tubes.  The thickness of the two TL-4 tubes totals 6-1./2” thick, compared to 4” for those of the TL-3.  The TL-4 is 33” high, compared to 29” for the TL-3.  Clearly, one would be hard pressed to tell which was when looking at one of them on a bridge. Therefore, my photo gave the Commissioners an accurate idea of the view through both versions of the Wyoming Rail.

Second, both the Wyoming TL-4 and TL-3 rails have passed current crash test standards and have been accepted by the Federal Highway System for use on the Federal Highway System.  As you may recall, the Caltrans engineer flatly stated that the Wyoming TL-3 rail that I showed the Commission had not passed the current crash tests and was not currently acceptable on the Federal Highway System.  When I returned home, I checked my files. My files confirm that Caltrans made a flat assertion to the Commission that is factually wrong. Caltrans has again demonstrated that its supposed experts know less about bridge railings and safety standards than does a lay person.

I have in my files a letter from Patrick Collins, State Bridge Engineer of the Wyoming Department of Transportation, that states in part, “…The railing shown … has been crash tested and accepted for Test Level 3 (TL-3) criteria, as noted in the enclosed letter for the Federal Highway Administration.”[1]  The TL-3 railing was the type of railing that I showed.  The letter from the Federal Highway Administration makes clear that the acceptance is based on current (Report 350) crash test standards:

The second railing, the Wyoming 2-tube, curb-mounted design, was previously accepted under the NCHRP Report 230 criteria.  This design … has now been tested sucessfully with the 2000-kg pickup truck, thus qualifying it as an NCHRP Report 350 TL-3 railing.[2]

Also, the Commission should be assured that a TL-3 railing is fully acceptable to the Federal Highway Administration (FHWA) for use on the Federal Highway System (FHW).  The quote below is from the most recent definitive statement by the FHWA on bridge railings:

All bridge railings installed on NHS projects let to contract after August 16, 1998, shall meet the acceptance criteria contained in NCHRP Report 350….  The minimum acceptable bridge railing will be a TL-3…[emphasis added][3]

I will be happy to provide full copies of the cited letters and document upon request.

Sara, as you are well aware by now, this incident continues the disturbing pattern of erroneous assertions by Caltrans that I documented in my request for revocation of the permit for the Noyo Bridge. These errors, put forth as fact with such certainty by supposed experts, greatly influenced the Commissioners in its initial decisions about the bridge and now threaten to do the same with respect to alternative railing designs.  As I said in my remarks on Tuesday, Caltrans cannot be trusted to present accurate information to the Commission.  Somehow, the Commission needs to obtain independent, expert review of Caltrans’s submissions to it.  I want to make clear that I am not offering myself as that expert.  I’m willing to continue to help with railing design, but obviously the problem goes far beyond the Noyo Bridge and scenic railings.

I would greatly appreciate your distributing copies of this letter to all Commissioners before the close of your current meeting.


Vince Taylor                           

1 Letter from B. Patrick Collins, Depatment of Transportation, Cheyenne, Wyoming, to Vince Taylor, May 20, 1999.

[2] Letter from Seppo I. Sillan, Acting Chief, Federal-Aid and Design Division,  FHA, to Vincent Shimmoller, Regional Administrator, FHA, Lakewood Colorado, July 1, 1996

[3] J.H. Hatton, Federal Highway Administration, “Bridge Railing Design and Testing, A Discussion with the AASHTO Highway Subcommittee on Bridges and Structures, Techical Committee (T-7) for Guardrail and Bridge Rail, May 14, 1996