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.
Sincerely,
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.