FTA: WHO or WHAT One Knows?

In 2011 the Federal Trade Administration (FTA) released a RFP to perform a study: Positive Train Control for Commuter and Regional Rail Systems. The stated objective of the RFP was to “evaluate the safety and reliability of PTC technology in commuter rail and regional rail operating environment, and to recommend the best practices in the implementation of PTC systems”. Without question, this proposed study had great potential benefit for commuter and regional rail operators. As such, the final report of the study was to be provided by June 30, 2013. After several years of seeing nothing from FTA, I confronted a FTA official as to the status of the report. I received no meaningful response (basically I was brushed off) , and I let ago of following this study as a fatuous effort by FTC that hopefully didn’t result in anyone being paid the $900k budgeted for the study.

Forward to July 2017 when the Final Report was released 4 years late: Technical and Safety Evaluation of the Southern California Regional Rail Authority PTC Deployment Project. Unfortunately, the study and the resulting Final Report was a total sham as demonstrated by the contents of the report as explained below.

To understand my issues with the study, I need to state first that I headed a team of well-experienced railroad consultants that responded to the RFP, and we were not selected. Not being selected is not the issue here IF indeed had a credible consultancy been selected. However, that is clearly NOT the case as I explain below. To be blunt, it appears to me that the selection of the University of Southern California (USC) team of professors was done by whom they knew, and NOT by what they knew. The proof of my position is readily noticeable in the report submitted by USC. I address 3 areas to make this point: PURPOSE, TIMING, & CREDENTIALS.

PURPOSE: It was clear to my team that the primary purpose of the study was to explore the issues of implementing PTC from a commuter and regional rail perspective, AND to present that information in a timely fashion that would be valuable to those operations. We knew that a primary issue would be the operating rules of these agencies were not being considered by the freight railroads via the Interoperability Train Control (ITC) committee. In fact, that has indeed been proven to be the case. In short, this means that the PTC handling of operating rules being deployed by freight railroads is not truly aligned with the requirements of the commuter railroads specifically. For example, consider the recent accidents within passenger terminals were the train accelerated resulting in fatalities. PTC if properly designed for commuters could readily have prevented this situation, but that was not done so by the freight railroad’s Interoperable Train Control (ITC) committee given its freight-only perspective. USC did not have the credentials, yet alone the insight to recognise this critical point.

Simply stated as to PURPOSE, the report is critically constrained for commuters in that it didn’t address critical PTC issues that are specifically oriented to such operations.

TIMING: The July 2017 report provided by USC was 4 years late, and hence is at best a “reactive” analysis versus a “proactive” analysis that could have been valuable to passenger operations. In short, this report is meaningless as to providing assistance to other agencies: the horse was already out of the barn, if you will.

Simply stated as to TIMING, the report was totally useless as to assisting the other passenger operations with their activities.

One has to read no further than the study’s ASTRACT to realize the lack of credentials of the USC team of professors without any notable railroad domain expertise. I quote: “Positive Train Control (PTC), often referred to as Communication Based Train Control (CBTC) …”. This statement is totally wrong and naïve as well; I don’t know how this major point got past the USC team of authors, as well as FTA. That is,

• PTC is a NON-VITAL, overlay enforcement system to prevent train accidents due to human errors.
• CBTC is a VITAL traffic control, management, and enforcement system

For my purposes here, VITAL is best defined as the means by which movement authorities are generated, i.e., the integrity of train movements, whether that be wayside equipment, office software, or an individual. PTC does not generate movement authorities and hence is not vital.

Simply stated as to CREDENTIALS, USC clearly did not understand PTC as well as lacking the ability to work with the PTC community as they stated in their report; they were shunned. They are outsiders without credible domain knowledge, thereby resulting in a useless analysis that provided no real value.

In conclusion, FTA awarded a project to USC that was not warranted at best, and that suggests irresponsible, if not unethical, practices by FTA as to the use of U.S. funds.

Given that there appears to be no current FTA Administrator, I submitted yesterday my letter of complaint (noting the above points) to the Associate Administers of Administration, Program Management, and Research, Demonstration and Innovation. I requested the courtesy of a response from these individual to explain how this study was awarded, apparently not monitored as to delivery (again, 4 years late), and yet accepted starting with the amazingly naïve, false equivalency of PTC to CBTC. So! Will one or more of them respond to my letter, and then proceed to have the report corrected? Or, will it be brushed under the rug and ignored since it is valueless?

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