The elixir of fatuous rationalization being served up by PTC-220,LLC to gain more spectrum in the name of PTC has been poisoning the efforts of both freight and passenger operations to cost-effectively meet the mandated implementation of PTC before 2016.
Point 1: In May 20011, the Federal Communications Commission (FCC) of the U.S. released WT Docket No 11-7, with Public Notice, regarding the “Spectrum Needs for the Implementation of the PTC Provisions of the Rail Safety Improvement Act of 2008”. Subsequently, in addition to my written response, a number of submissions were made by various parties, most notably several passenger operations and PTC-220, LLC (the entity owned by BNSF, CSX, NS, and UP that owns and manages the 220 MHz spectrum to be used for the implementation of PTC). The FCC’s Docket was the result of the request by PTC-220 to obtain additional spectrum in the same band reportedly to service both the freight and passenger rail requirements of the PTC mandate.
Point 2: At the end of 2010, the Federal Transit Authority (FTA) released several RFQ’s for studies to be performed relative to PTC and CBTC. The primary study was to evaluate the issues associated with implementing PTC on commuter and regional rail systems. As I will be explaining in a posting I will be making shortly, this effort by the FTA is a very pathetic example of how a Federal agency can spend a fair amount of money and achieve nearly nothing of interest to the intended recipients. The proposal was poorly written as to both objectives and understanding of the subject, along with a process for evaluating and awarding the contract that was clearly inappropriate and unfair. (Yes! My team’s proposal was not selected. But, I will explain the madness of the process in the forthcoming posting). The point for now is that in preparing the proposal, my team discussed the wireless issues with a number of passenger operators and gained some understanding in a very short period of time as to the concerns that they have as to the use of 220 for PTC.
To be addressed in greater detail in the forthcoming issue of my quarterly journal, Full Spectrum, titled Wireless Gone Awry, I will highlight below a number of points as well as statements that PTC-220 made in their submission to the FCC’s Public Hearing, that are critical to understand in consideration of providing more 220 to PTC-220.
- First of all, I am not saying that PTC-220 is incorrect in requesting more spectrum if they really need it. However, by their own admission, they really don’t know what they need in that they have not done any credible data modeling relative to PTC. They are spectrum hungry and may even be looking at this spectrum as a “for profit” operation for dealing with the passenger operators.
- In their submission, PTC-220 likened PTC to advanced traffic control / management systems and the need for complex wireless networks to service the latter. I find such a comparison either to be shamelessly naïve or quite devious.
- The passenger operators have been led to believe by PTC-220, reportedly, that they must obtain 220 specifically for their own property to be compatible with the freight railroads. Hence, from some of the submissions by passenger operations, it appears that they were pressured, or unfairly influenced, to support PTC-220’s position. The requirement to use 220 only is clearly incorrect and could be very costly for those operators that will be extremely pressed to find the public funds to implement PTC.
- PTC-220 states that they had engaged TTCI (which is operated by the AAR and hardly free of conflict of interest), to perform data modeling nearly 6 months prior to the submission, and yet there were no results that they could include in the submission. Really? I have team members that could handle that analysis quite quickly.
- The onboard PTC platform, a.k.a. TMC, incorporates a Mobile Access Router (MAR) that supports the use of alternative wireless paths, including 220, WiFi, and cellular.
- The rail industry is poorly utilizing a fair amount of spectrum, including conventional 160 MHz instead of trunked operation, 44 MHz now owned by PTC-220 and which was the choice of BNSF for PTC, and 900 MHz that was given to the railroads 2 decades ago to do ATCS. ATCS was never implemented and the railroads have used the spectrum for business purposes instead of giving the spectrum back (BTW, using 900 for code line is a business decision and not a safety one).
In summary as to the above, PTC-220 should be required to define their requirements clearly and with the proper level of legitimate data analysis done by an independent entity. As a point of further consideration, there is also a need to break down that requirement as to the type of traffic control involved as well as traffic density. For example, deploying PTC across dark territory has a substantially different wireless requirement than deploying PTC across signaled territory with either medium or heavy traffic volumes. In short, there is a need to identify various PTC “wireless corridors” as to throughput and coverage requirements, and to model them individually.
In addition to my initial submission, I made a subsequent submission commenting on the falsehoods and misrepresentation that were made in some of the other submissions, most notably PTC-220. Additionally, 2 weeks ago I made a presentation to the FCC to provide them with a modicum of rail domain knowledge that would assist them in understanding the true requirements of wireless for PTC.
Both of my submissions as well as the presentation to the FCC were on a fee basis for a client, Skybridge Foundation. SBF placed no restrictions on what I wrote / presented, and did not interfere with the objectivity of my material. Both of those submissions and a PDF of my presentation are of public record and can be obtained via the FCC’s website or by emailing a request to me at email@example.com. Additionally, those individuals that seek to further understand wireless corridors are encouraged to contact me on that topic as well.