Huie Comment Resolution ST-125 Triennial Security Review of San Diego Trolley, Inc
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2009

TRIENNIAL SECURITY REVIEW OF

SAN DIEGO TROLLEY, INC.

(SDTI)

RAIL TRANSIT SAFETY SECTION

RAIL TRANSIT AND CROSSING BRANCH

CONSUMER PROTECTION AND SAFETY DIVISION

CALIFORNIA PUBLIC UTILITIES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102

June 29, 2009

(PUBLIC)

Richard W. Clark, Director

Consumer Protection and Safety Division

2009 SECURITY REVIEW OF

SAN DIEGO TROLLEY, INC.

(SDTI)

ACKNOWLEDGEMENT

The California Public Utilities Commission's Rail Transit Safety Section (RTSS) staff conducted this system security program review. Staff members directly responsible for conducting review and inspection activities include:

TABLE OF CONTENTS

   

Page

1

EXECUTIVE SUMMARY

1

2

INTRODUCTION

2

3

SDTI BACKGROUND

4

4

REVIEW PROCEDURE

6

5

FINDINGS AND RECOMMENDATIONS*

7

     
 

APPENDICES

10

A.

Acronyms List

11

B.

SDTI 2009 Security Review Checklist Index*

13

C.

SDTI 2009 Security Review Recommendations List*

14

D.

SDTI 2009 Security Review Checklists*

15

* These sections are included in attachment B and contains Sensitive Security Information (SSI) that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know" as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the transportation security Administration or the secretary of Transportation. Unauthorized release may result in civil penalty or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C. 552 and 49 CFR parts 15 and 1520.

The California Public Utilities Commission's (Commission) Consumer Protection and Safety Division (CPSD), Rail Transit Safety Section staff (staff) conducted an on-site security review of San Diego Trolley, Inc. (SDTI) in June 2009. The review focused on verifying the effective implementation of the Security Emergency Preparedness Plan, addressing Threat & Vulnerability Assessment (TVA) and emergency response.

Following the on-site security review, staff held a post-review conference with SDTI personnel on July 17, 2009. Staff provided the SDTI Chief Executive Officer and Chief of Transit Security a preliminary summary report detailing the on-site review recommendations for corrective actions.

The security review results indicate that SDTI has a comprehensive Security and Emergency Preparedness Plan (SEPP) and has effectively carried out that plan. Staff found SDTI's progressive and effective security program very concise and efficient. Staff exceptions found during the review are described in the Findings and Recommendations section of each checklist. Of the 9 checklists, staff made 7 recommendations for corrective action.

The Introduction for this report is presented in Section 2. The Background, in Section 3, contains a description of the SDTI rail system and the Review Procedure is in Section 4. Section 5 contains the Findings and Recommendations.

The Acronyms listing is in Appendix A and the SDTI 2009 Triennial Security Review Checklist Index and Recommendations List are included in Appendices B and C respectively. The Security Review Checklists are presented in Appendix D.

2. INTRODUCTION

The Commission's General Order (GO) 164-D, Rules and Regulations Governing State Safety Oversight of Rail Fixed Guideway Systems, and the Federal Transit Administration's (FTA) Rule, Title 49 Code of Federal Regulations (CFR) Part 659, Rail Fixed Guideway Systems: State Safety Oversight, require the designated State Safety Oversight Agencies to perform a review of each rail transit agency's system safety and security program(s) at a minimum of once every three years. The purpose of the review is to evaluate the effectiveness of each rail transit agency's SEPP and to assess the level of compliance with GO 164-D as well as other Commission safety and security requirements.

On May 22, 2009, staff sent a letter, along with thirty two safety (32) and nine (9) security checklists, to the SDTI Chief Executive Officer, advising SDTI that the safety and security annual review would be scheduled June 22 to 26, 2009. Staff subsequently confirmed specific dates and times with the SDTI Office of Health and Safety.

An entrance meeting held on June 22, 2009, including executive level management and representatives from CPUC, SDTI, MTS, and San Diego

Association of Governments (SANDAG) preceded the records reviews. Staff provided preliminary review findings and recommendations to SDTI and SANDAG management and representatives at the exit meeting on July 17, 2009.

Staff performed the on-site security review at SDTI's 1255 Imperial Ave office on June 29, 2009. Staff utilized nine (9) checklists for the inspection of the Security and Emergency Preparedness Plan. Staff derived the checklist review questions from CPUC's GO 164-D, FTA's 49 CRF659, Transportation Security Administration's (TSA) Baseline Security Review, SDTI's SSPP and SEPP, Federal Transit Administration (FTA) FTA-TRI-MA-7085-05 and FTA Transit Agency Security and Emergency Management Protective Measures dated Nov. 2006.

3. SDTI BACKGROUND

SDTI Rail System Description

The SDTI LRT system operates over 53.5 miles on three routes, mostly double-tracked, with 53 stations. Weekday ridership averaged 82,589 in 2009 (Fiscal year), with a total of 36.9 million riders carried in 2009 (Fiscal year). SDTI's rail lines are classified as "light rail" on semi-exclusive right-of-way. There is a shared corridor with BNSF, Amtrak, and Coaster trains beginning at Park Blvd/Harbor Drive on the Bayside Corridor going through the Old Town Corridor parallel to Pacific Highway and ending approximately a quarter mile north of the Taylor Street grade crossing. In addition to the shared corridor, portions of SDTI track on the Blue and Orange Lines are jointly used by light rail transit and freight operations under scripted temporal separation with limited night-time joint operations. The San Diego and Imperial Valley Railroad (SDIV), a subsidiary short line railroad owned by Rail America Corporation, shares track with SDTI on the Blue line from the Imperial Transfer Station to the International Border. SDTI and SDIV share track on the Orange Line from Commercial Street at the Imperial Junction to Bradley Avenue in El Cajon, California. Freight operations by SDIV operate during the early morning hours with a fringe period of overlap with SDTI light rail transit operations under a Federal Railroad Administration (FRA) waiver. FRA approved SDTI standard operating procedures ensure during this mode of operation of overlap that the light and conventional rail vehicles remain spatially and temporally1 separated.

SDTI Lines

SDTI operates three lines described as:

4. REVIEW PROCEDURE

Staff conducted the 2009 security review in accordance with Rail Transit Safety Section Procedure No. 4, Procedure for Performing Triennial Safety & Security Reviews of Rail Transit Systems. Staff developed nine (9) checklists to evaluate the adequacy of SDTI's Security and Emergency Preparedness Plan and the efficacy of its implementation.

The security evaluation includes the SDTI's security department, programs and processes which have system security functions and responsibilities. The security review is based on Commission and FTA requirements, SDTI's SEPP & SSPP, American Public Transportation Association (APTA) system safety program guidelines, TSA baseline review list, TSA security related documents, Federal Transit Administration (FTA) FTA-TRI-MA-7085-05, FTA Transit Agency Security and Emergency Management Protective Measures Nov. 2006, and the staff's knowledge of the transit system. The nine (9) checklists are listed in Appendix B.

Each checklist identifies the core security-related elements and characteristics that staff reviewed. Each of the checklists also references Commission, SDTI, and other documents that establish the security program requirements. The methods used to perform the review include:

Immediately following the security review, staff summarized the findings and the preliminary recommendations with SDTI's Chief of Security. The post-review summary is beneficial for clarifying findings or best-practices and provided SDTI an opportunity to promptly address any necessary security improvements.

5. FINDINGS AND RECOMMENDATIONS

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APPENDIX A

   

Page

A.

Acronyms List

11

B.

SDTI 2009 Triennial Security Review Checklist Index

13

C.

SDTI 2009 Triennial Security Review Recommendations List

14

D.

SDTI 2009 Triennial Security Review Checklists

15

ACRONYMS LIST

Abbreviation

or Acronym

Definition

CAP

Corrective Action Plan

CEO

Chief Executive Officer

CFR

Code of Federal Regulations

Commission

California Public Utilities Commission

CPSD

Consumer Protection and Safety Division

CPUC

California Public Utilities Commission

CTC

Centralized Traffic Control

DHS

Department of Homeland Security

ERP

Emergency Response Plan

FTA

Federal Transit Administration

GO

General Order

ICS

Incident Command System

ISA

Internal Safety & Security Audit

MOU

Memorandum Of Understanding

MTDB

Metropolitan Transit Development Board

NIMS

National Incident Management System

PC

Penal Code

POST

Peace Officer Standards and Training

RCS

San Diego Regional Communications System

RTCB

Rail Transit and Crossing Branch

RTSS

Rail Transit Safety Section

SANDAG

San Diego Association of Governments

SCADA

Supervisory Control And Data Acquisition

SCIC

Security and Critical Incident Committee

SDCSD

San Diego County Sheriff's Department

SDTI

San Diego Trolley, Inc.

SSI

Sensitive Security Information

SEPP

Security and Emergency Preparedness Plan

SSPP

System Safety Program Plan

Staff

California Public Utilities Commission Staff

TSA

Transportation Security Administration

TVA

Threat & Vulnerability Assessment

UDC

Unified Disaster Council

APPENDIX B

SDTI 2009 ANNUAL SECURITY REVIEW CHECKLISTS INDEX

(CONFIDENTIAL)

APPENDIX C

SDTI 2009 TRIENNIAL SECURITY REVIEW RECOMMENDATION LIST

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APPENDIX D

SDTI 2009 TRIENNIAL SECURITY REVIEW CHECKLISTS

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1 Temporal separation exists when no simultaneous operation of rail transit and freight trains on the same tracks occurs

2 CPUC General Order 143-B, §9.04 Alignment Classification: Semi-exclusive is 1) fully exclusive right-of-way with at-grade crossings, protected between crossings by a fence or substantial barrier, if appropriate to the location. 2) Within street right-of-way, but protected by six-inch high curbs and safety fences between crossings. The safety fences should be located outside the tracks. 3) Within street right-of-way, but protect by six-inch high curbs between crossings. A safety fence may be located between tracks. 4) Within street right-of-way, but protected by mountable curbs, stripping, or lane designation.

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