Strategic Railroading

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There is unlikely to be anyone significantly involved with the U.S. freight industry that has not been exposed to the phrase railroad interoperability given the Federal mandate of Positive Train Control (PTC), an overlay enforcement system. This mandate, via the Rail Safety Improvement Act of 2008, has consumed extensive capital and human resources of the railroads and selected suppliers to design and implement PTC before 2016 in such a fashion that the movement across railroad borders will be transparent to the on-board PTC system. This transparency of interchange, a.k.a. railroad INTERoperability, is unprecedented in the U.S. as to both technologies and cooperation between the railroads, and only exceeded by the European countries in their development and deployment of ETCS, a traffic control system with integrated enforcement. However, unlike ETCS which has been handled by the supplier community, PTC is primarily an effort of the 4 primary Class I railroads, much to dismay of the commuter railroads that are basically at the mercy of what the Class Is provide (see a previous posting on this blog: A Wag of the Finger).

While providing for PTC interoperability across railroads is an extraordinary effort for which the Class Is deserve tremendous credit for addressing the technology challenges (albeit a tremendous overkill as to wireless – see previous posting: Don’t Drink the Kool Aid), the railroads are failing to an equal or even greater extent to address the functionality issues of this effort that are available to them. That is, the technicians for PTC are doing what they are required to do to address PTC functionality, but the Class Is’ senior management teams are not considering what can be achieved across the industry as to operations and resource management given the wireless network that is to be deployed for PTC. I refer to this industry-wide functionality as Industry INTRAoperability (I/I) as was introduced in the FRA-funded study I performed in 2008: A Demand and Supply Analysis of the Opportunities for Wireless Technologies in Passenger and Freight Rail Operations (www.fra.dot.gov/downloads/Research/ord0802.pdf).

So! Why are railroads not pursuing I/I ? The answer involves two components. First, railroad executives are highly motivated, if not exclusively so, by the executive bonus programs that are provided them. Second, to pursue I/I requires resources that are not generally available in the railroads, i.e., technologists (not technicians) that can envision and develop cost-effective, strategic technology plans in sync with strategic business plans, a.k.a. Strategic Railroading. As to both of these components, I offer a primary example.  If railroads truly wanted to pursue scheduled operations, then to do so would mean that the railroads with which they interchange must be striving for schedule operations as well. That means reliable cooperation within and between roads . . . which means that the executive bonus programs must be so structured  – but they aren’t.  If they were, then perhaps the railroads would provide for the second component, the technologists that could work together just as the technicians from the railroads have been doing for the last several years to pursue railroad interoperability for PTC deployment.

So! How can I/I be pursued given the lack of both appropriate executive bonuses and technologists?  The answer to this question is two-fold: 1. Education and 2. Process.  Both of these points will be addressed in the next two postings to the blog. So! Please check back into this blog during the next several weeks.

One of President Reagan’s qualities was his wit, including this glib quote: “The nine most terrifying words in the English language are: ‘ I’m from the government and I’m here to help.'”  When it comes to railroad operations and Federal formal involvement via regulation, there should be no question in anyone’s mind as to the critical role that the FRA provides in ensuring safe railroad operations. I’ve seen the horrific operations of railroads in countries, including my current assignment with the Egyptian National Railways to advise on their safety (including  PTC) and efficiency of operations, that are without such oversight.  However, there are upper and lower limits as to what the government can and should do. For example, the often-heard statement of “We have 0% tolerance for unsafe operations” by regulators is clearly not objective, yet alone achievable.  A more truthful statement, but with much less PR effectiveness, would be to state that the regulation of railroads is a tradeoff between costs and the level of safety achieved; a pursuit of diminishing returns.  It should not be a matter of safety at any price.

As to an upper limit of the Federal government intruding upon railroad operations, arguably the most abusive lately is the U.S. Federal government’s mandate to implement PTC before 2016. This knee-jerk reaction by Congress (with President Bush’s signature) to the horrific September 2009 accident between Metrolink and UP, was way over the line as to an objective, pragmatic understanding and thinking as to the safety value of PTC relative to the cost of its deployment. This was not a matter of irrational action on part of the FRA, who had in fact made an honest attempt a number of years earlier (with the participation of railroad management and Labor) to compare the safety benefits of PTC to its costs. That analysis left no doubt that PTC was not justified as to the safety benefits it delivered. That doesn’t mean that a railroad would not want to implement PTC from their individual perspective as is apparently true of BNSF’s pursuit of PTC prior to the mandate. As a side note when last checked, the FRA’s website still foolishly stated that PTC provides for business benefits. (For readers of this posting outside of the U.S., please note that PTC can be deployed in a cost-effective fashion. But that is not the case in the U.S. with technicians-gone-wild as discussed in other postings on this blog.)

So! Based upon my fuzzy feelings for the FRA, I foolishly thought that the same value points of the FRA would apply to the Federal Transit Authority (FTA).  How, so very wrong I was. Unlike the PTC mandate that was an over-kill as to Federal involvement, a recent PTC study RFP released by the FTA was a tremendous under-kill, if you will. The FTA is actually failing to take enough action to support the passenger rail operations with the activities required to meet the PTC 2016 deadline. That doesn’t mean that the FTA isn’t providing $s to provide assistance. Sadly, they are providing $s (as provided in the mandate) to engage contractors without any credible evidence of their capabilities other than knowing the right folks, In My Humble Opinion (IMHO) .  It seems to be the perfect example of the old chestnut: “It’s not what you know, but who you know.”

Without going into great depth, the PTC study RFP released at the end of 2010 had the following issues:

1. It was poorly written given the objectives that were stated were both totally unnecessary (e.g. the study was to develop a template for a PTC Implementation Plan (PTCIP) that had already been accomplished 8 months prior, and incomplete in missing the primary challenges to be confronted by the transits.
2. The RFP was specifically designed to deal with only one transit’s particular requirements, without the provisions to address the full spectrum of challenges, most notably the full spectrum of specific functionality that each transit requires for the use of PTC that are not being addressed by the freight railroads.
3. The awarded contractor, University of Southern California (USC), has no known experience in PTC, yet alone primary railroad operations, IMHO.
4. A clause was inserted in the RFP which prevented any competition, any consideration of credible proposals, other than that of the organization that Metrolink had selected as their desired contractor, IMHO. I refer to the following extraction from the RFP: the successful contractor must show that a “positive relationship (must exist) between grantee and the rail transit authority”. When Metrolink was approached to participate by at least one contractor, they were summarily rejected without any consideration of their credentials.  In short, by default, Metrolink made the decision which contractor would be awarded this contract without objective evaluation of the other proposals.
5. APTA (the American Public Transit Association) that represents the interests of the transit industry overall, along with the individual transits subjected to the PTC mandate, have noted between themselves that the lengthy duration of the study, as well as the focus on Metrolink, provides no effective value to the other 20+ transits.

This FTA-funded study is in effect an outrageous $900,000 gift to the folks at USC to produce nearly no value relative to the major issues with which the other transits are confronted to implement PTC, most notably the proper use of wireless technologies and the functional issues of importance to the passenger rail industry for the deployment of PTC.

Lastly, when asked if they would consider a protest as to their selection process based upon the above, FTA’s response was a resounding NO.  Of course they would say that. It is embarrassing enough as to how they handled the situation without any further consideration on their part of the logic and legitimacy of how the study was both structured and awarded, IMHO.  This FTA study is a shameful example of what should not be taking place in our country. The U.S. tax dollars are being totally wasted. So! Does FTA have the intestinal fortitude to restructure , or kill, this currently meaningless study for the benefit of the industry that it serves?

As Cobert would say “A Wave of the Finger to FTA”.

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 comarch@aol.com. Additionally, those individuals that seek to further understand wireless corridors are encouraged to contact me on that topic as well.

In designing and implementing safety systems, risk assessments are made to identify and mitigate unsafe situations so as to ensure a certain level of safety is achieved (a level of risk is not exceeded). For traditional railroad signaling systems, each supplier in the North America has developed its individual qualitative approach referred to as V & V (validation & verification) for evaluating their respective systems. That is, the V&V process is meant to validate that the right thing is being done, and then verify that it was done correctly. For electrical / mechanical components and systems, such an approach makes sense.  But, when a most complex and highly unpredictable variable such as the human is introduced as part of the system, then the V&V process is not sufficient; the risk assessment process becomes much more risqué.

The design and implementation of Positive Train Control (PTC) has taken the traditional signaling suppliers outside of their comfort zone for risk assessment. With PTC designed to prevent the failures of humans to operate their trains within the limits of the active movement authorities, means that a qualification process has to be complimented with a quantitative process as well.  But, if humans are so unpredictable as to both the types and occurrence of errors that can be made, then how can even a quantification process be established?  Actually, the process is quite straightforward. It’s a matter of simulating the environment to be evaluated over an extensive period of time and/or iterations, and to use historical data as to the type and degree of threats that may occur.  The reason for the extensive time period and/or iterations is to provide for the randomness of events so as to ensure a statistically sound analysis.

Risk relative to evaluating PTC was defined by the Railroad Safety Advisory Committee (RSAC) to be the severity multiplied by the likelihood of the train being coincident in time and space with an unsafe condition. RSAC was composed of a mixture of regulators, rail management, labor, and supplier personnel, and one of their responsibilities was to evaluate a risk assessment process that was being specifically designed for PTC. Referred to as the Axiomatic Safety Critical Assessment Program (ASCAP), this tool was to be a very straightforward simulation program that could have readily provided a more than adequate analysis of PTC reducing risk – which everyone already intuitively understood anyhow.  I mean, if PTC eliminates the most dangerous source of train accidents, again human errors, then it’s a winner (assuming it doesn’t introduce any significant risk – and it doesn’t). Of course, the regulators can’t accept intuitive analysis. They need the mathematical proof, and hence ASCAP.

You noticed that I said that ASCAP could have been a great tool. But, it failed to be delivered due to extremely poor management of resources.  I am not referring to ASCAP’s developers, but rather to involvement by the RSAC participants that continuously battered the developers with “insights” and additional requirements of how to make the ASCAP simulate a railroad to the greatest exactness possible. What they failed to understand was that the error associated with simulating human-based events was much greater than correcting for the acceleration of a sample train from a railroad yard, for example.The bottom line here is that the RSAC advisors who were lacking in sound mathematical principles, including Operations Research (OR), and simple pragmatic analytical tools turned a straightforward simulation tool into an unachievable, complex quagmire of code. What was missing was a manager experienced in OR with railroad domain knowledge that could have separated the RSAC’s advisors appropriate advice from the fatuous comments.

ASCAP failed due to poor management and not due to its concepts or principles. Simulation is a quantification risk assessment approach that eliminates the risqué-ness in risk assessment processes involving humans.

The concept of interoperability is relatively new to the rail industry as railroads link their operations within and across country boundaries. In fact, the lack of interoperability between various European countries in the past century was a purposeful defense mechanism against invading armies that could use railways for rapid, massive troop and weapon movements. Now, interoperbility has been the driving force for deploying ETCS across Europe for the past decade or so.  And in the U.S., interoperability is currently the most costly and exasperating aspect of delivering Positive Train Control to meet the U.S. government’s mandate of it being implemented across most of the country’s trackage before 2016. Specifically as to PTC, the Interoperable Train Control (ITC) committees that are primarily manned by CSX, NS, UP, & BNSF have been working intensely to address issues such as system architecture, on-board functionality, message set, communication network, data management, and an all-encompassing method of operation.  However, what has not been addressed is dealing with the set of parameters that provide for interchangeability, i.e., the ability to exchange a component or entire on-board PTC unit when not on the owning railroad’s property. Actually, this can even be an issue within an individual railroad as is currently the case with one Class I railroad that has an inventory of on-board units with 8 different model #s.  Clearly, as the railroads begin to implement PTC, the challenges of interchangeability, and hence the costs, if not handled properly very soon, are going to grow exponentially.

The parameters of interchangeability include the physical dimensions, electrical interfaces, as well as ensuring software and hardware compatibility at both the component and platform level.  Perhaps some folks think that the issue of PTC interchangeability will not be that significant given that Wabtec is the only supplier of the on-board Train Management Computer (TMC).  However, that point is quickly dismissed based upon a number of other considerations, including

• Other suppliers are looking to compete with Wabtec as to the TMC;
• Again, one Class I railroad already has 8 different model #’s for the Wabtec TMC;
• Railroads will want to ensure that a foreign unit is properly configured as to software and hardware;
• Railroads will want assurance as to a long-term supply of components and units;
• There is a vast number of individual locomotive configurations;
• Proprietary backplanes work against the railroads’ best interests in most cost-effectively deploying on-board systems;
• Lastly, given that industry politics seemingly are always at play, there are bound to be conflicts within the “standards” that are being provided by ITC. BTW, what about the one most critical standard that is not being provided by ITC.  I refer to the TMC source code.  More on this latter.

Volume 59 of my quarterly publication, Full Spectrum, that will be released around October 1^st this year, will be addressing interchangeability in substantial detail as to the challenges and the opportunities.

In the November 2002 issue of Harvard Business Review (HBR) there was an article titled “The Six IT Decisions Your IT People Shouldn’t Make”. It was a great article about how Operations management for so many companies have abdicated responsibility for IT decisions to IT executives, thereby resulting in a significant loss in the return on their IT investments.  The underlying truth is quite straightforward. That is,  Operations management “failed to recognize that adopting systems posed a business – not just a technological- challenge. Consequently, they didn’t take responsibility for the organizational and business process changes the systems required.”   The result of this lack of involvement was that the CIO, with a technology perspective exclusively, was constraining the advancement of the company’s business processes, and most likely the return on IT investment and, more importantly, the company’s bottom line.

Shift now to railroads and their nearly total dependence on managing mobile and remote resources. In this environment, the strategic IT environment extends to the “mobile node”, the locomotive platform, by incorporating a strategic wireless data perspective in sync with the IT strategy. And, has been so unfortunately demonstrated in the North American railroad industry, it’s the wireless technicians that are constraining the advancement of business processes by their pursuit of non-strategic wireless networks, most recently in the name of PTC.  I refer specifically to the intended deployment of the 220 MHz band in parallel with the 160 MHz band that will be shifting to a digital platform to meet the FCC’s narrow-banding mandate. In line with the HBR article, the railroads’ Operations management have not been involved with the evaluation of how wireless technologies will be deployed. I stress that it is not the technicians’ fault that they have such a free hand, but rather that of the railroads’ upper management that have failed to be involved.

Paraphrasing the key points of the HBR article, below are the 6 decisions that a wireless manager should not make about the deployment of wireless technologies, from both a strategy and execution standpoint.

Strategy

• How much should we spend on wireless?
• Which business processes should receive our wireless dollars?
• Which wireless capabilities need to be company-wide ( and industry-wide)?

Execution

• How good do our wireless services really need to be?
• What security and privacy risks will we accept?
• Whom do we blame if a wireless initiative fails?

Via several following postings to this blog, I will address some of these questions in greater detail.

With a cost / benefit ratio of 20/1, there is no incentive for railroads to implement PTC on their own. As discussed in a number of postings on this blog, there are no business benefits provided by PTC directly, in that PTC has nothing to do with the efficiency of traffic management. Some folks are still confused on this point in that they refuse to accept the fact that it is the wireless data system that PTC requires which can deliver data required for advanced resource management, as in “Where is my train and how fast is it moving”.  PTC is just one user of the wireless network.  This point has been well demonstrated by Norfolk Southern, that by means of a simple wireless data system, is currently implementing proactive traffic management before and without PTC. However, there is, or rather there was before the mandate, a possibility of railroads to achieve indirect business benefits from the deployment of PTC.

Prior to the mandate, there had been some possible movement in the FRA to consider the overall risk of a track segment as to whether or not a combination of changes could be made that may have a NET decrease in risk even though one or more of the changes may actually increase risk, e.g., removing signals that were no longer required … or … making the transition to one-man crews. HOWEVER, by implementing PTC in concert with doing either or both of those would result in a net decrease in risk given the safety value of PTC that prevents train crew errors. Therefore, prior to the mandate, implementing PTC provided the railroads with the possibility to implement other projects of significant business value that may not have been accepted by the FRA otherwise. With the mandate, the railroads no longer have that bartering position … or maybe they do.

Jumping to the present, and again thinking about the PTC mandate and the phenomenal cost for which the railroads so far are near-totally responsible, then perhaps a concept can be brought to the table to ease the financial blow of the knee-jerk PTC mandate by Congress due to the Metrolink-UP accident in September 2008. I am referring to the railroads being given Risk Credits relative to their degree of PTC implementation. That is, for every segment of PTC installed, then the railroads get a certain amount of risk credits to use for the pursuit of other activities that may be deemed to increase risk, but provide substantial business benefits, again one-man crews, removing signals, whatever. Such credits, like pollution credits, may even be tradable between railroads by those who don’t need the credits and those that could use them. Hmmmmmm! Great Idea, me thinks. Spread the word.

ACT NOW! Don’t wait any longer. This is your last chance opportunity to get PTC before the technicians take your railroad to the edge of the PTC investment abyss and give you the financially-fatal push.

The PTC approach being pursued by the Class Is via the Interoperable PTC Committee (ITC) manned by CSX, UP, BNSF, and NS, is tremendously overdesigned as to functionality, technology, and infrastructure. The net of this is a 5-fold increase in investment (my estimate). However, it still is not too late to scream “ I’m not going to take anymore!” and design your PTC implementation in a fashion to avoid most of the unnecessary stuff.  Here’s the story in 3 simple bullets.

• As was addressed in an earlier posting on this blog, YOY WIUs, it is clear that the recent estimate of 50,000 wayside interface units (WIUs) that provide wireless data paths from wayside infrastructure components to the PTC client on the locomotive and the PTC server in the office is off by a factor of 60%, minimum. As explained in the earlier posting, WIU’s are not required for Intermediary Signals (ISs) and control points. The former is not a required function of the PTC mandate (in fact, doing so may actually increase risk), and the latter can be done via the already installed code line.

• I find no evidence of anyone doing an actual data throughput analysis for PTC. From my personal experience, having been the architect for the first overlay PTC system that provided the foundation for the Class I pursuits, there is very little data throughput required (save track data base downloads that can be handled via WiFi in the yard).  And yet, the ultimate wireless data system is being developed by ITC.  It is clear that PTC has nothing to do with this development in actuality. The railroad technicians want the network (they love the challenge), and perhaps someday they will need it (there currently is little to no strategy as to how the network could be used), and they are using PTC as the excuse.

• Complimentary to the above point, the railroads actually don’t even need the 220 MHz network.  What they failed to do several years ago was to use digital trunked radio technology to outfit the current analog 160 MHz infrastructure to meet the FCC’s narrowbanding requirement.  They are already switching that network from analog to digital, but they have chosen to use conventional radio instead of trunked. Granted it would have been a complicated transition, but $1 billion cheaper by avoiding the 220 MHz infrastructure. Again, the railroads’ technicians took it upon themselves to address challenges without proper executive management understanding and oversight which would have required proper business case analyses.

The bottom line on the railroads’ bottom lines is that the cost of PTC implementation could be reduced from the estimate $10 Billion to a mere $2 billion, give or take a $1 billion. But to take advantage of this Spring reduction, someone has to stand up now and say scrap the 220 MHz, install digital trunk 160 MHz, and ignore 60% of those WIU’s.  Of course that won’t happen. What a shame.

Ron Lindsey was recently commissioned to write a white paper titled ” Wireless for Railroads”.

The paper addresses the extraordinary opportunities railroads have, both individually and collectively as an industry, to advance their operations via the use of advanced wireless technologies, as well as to improve the efficiency of their spectrum usage. This perspective is expanded to consider the relationship of the freight rail industry with passenger rail, other transportation modes, and the intersection with public safety. This is a STRATEGIC PERSPECTIVE based upon identifying both the DEMAND for and SUPPLY of wireless technologies which provides the basis for structuring an approach for MOVING FORWARD.

The white paper will soon be available for download. But, to request an exclusive advance copy email Ron Lindsey at comarch@aol.com

In a previous posting on this blog, Hey! Watch This, I reported on some of the findings stated in the U.S.’s General Accounting Office (GAO) report on PTC dated December 2010. The bottom line of that report was that the cost / benefit ratio over 20 years for implementing PTC is hovering around 20/1; an absolutely unacceptable criteria for private investment. And yet, that is the burden, the cost of doing business, for the freight railroads it seems. For the commuter and regional rail systems that require public funding to stay in gear, the challenges of obtaining the necessary funding are likely to be even more severe. Given these circumstances, the question needs to be asked as to what can be done (other than obtaining Federal funding) to make the cost/benefit ratio more reasonable.

The opportunities to obtain a more reasonable cost/benefit ratio fall into three categories obviously, i.e., reduce the costs, increase the benefits, or do both. Until now, the only focus has been on increasing the benefits. However, as I have noted in the referenced posting, as well as others on this blog, there are no business benefits directly associated with PTC; PTC is only a safety-enhancement system. Those fatuous attempts by either naïve or mischievous individuals to identify business benefits have been rejected mostly by now, with only the occasional exception as discussed in my posting, Really! You Gotta Let It Go. So, the safety benefits that have been identified for PTC are all that there are.

So! If the benefit denominator of the cost/benefit ratio can’t be increased, then the only option is to decrease the cost numerator. Interestingly, there are three very significant ways to do that, although they still may not provide a reasonable cost/benefit ratio.  The first possibility, again, has been addressed on this blog already. I am referring to tightly integrating the PTC platform with an IT / wireless data platform to provide a mobile node architecture for a railroad’s management system just as a manufacturer would do with fixed nodes to manage its facilities.  The second possibility to reduce costs is to go after the wireless infrastructure that is being developed by the Class Is. As also addressed on this blog, this network is a tremendous overkill for what is needed for PTC as currently structured. And as will be described immediately below, the wireless infrastructure is even more irrational if the third method of reducing costs is taken into consideration, i.e., significantly reducing the number of Wayside Interface Units (WIUs).

Why Oh Why the WIUs ?

The implementation of PTC requires 4 primary components.

1.       On-board PTC platforms (clients);

2.       A back-office PTC platform (server);

3.       Wayside interface units that provide for the interchange of data between the critical wayside infrastructure components and the PTC clients / server; and

4.       A wireless communication network to deliver the necessary data between the other 3 components.

There simply is no way to reduce the number of PTC clients or to eliminate the server. However, when it comes to the WIU’s there is in fact a major opportunity to minimize the number of units required, that is if one doesn’t accept what is being said by the industry. Specifically, the estimated number of WIUs that will need to be installed to implement PTC across the U.S. has gone from 75,000 for shock value by the freight railroads following the mandate, to the current estimate of 50,000. Now, with the recent agreement by the Obama Administration to reduce the amount of trackage requiring PTC by 10,000 miles, due to changes in traffic by 2016, the estimated requirement for WIUs is probably now around 45,000.  But, the kicker is that such a number is still way too high, at least from a regulatory standpoint.

To understand what can be done to reduce the WIU requirement first requires understanding the functionalities that are provided by the use of WIUs, as follows:

1.       Reporting status of a manual switch to the PTC server for routing a train in dark territory;

2.       Reporting status of a manual switch to the PTC server or clients for supporting enforcement of a train to prevent unauthorized movement  through a misaligned switch;

3.       Reporting aspects of the control points to the PTC server or clients so as to set up the “targets” for possible enforcement; and

4.       Report aspects of the intermediary signals (ISs) to the PTC server or clients so as to set up the “targets” for possible enforcement.

There is a 5^th functionality supported by the use of WIUs that is not directly associated with PTC deployment, i.e.

5.       Permitting the operator to operate a switch remotely from the locomotive either within the train’s authority if PTC is operable, or without checking for authority should PTC not be available.

Now, like everyone else, did you accept #4 regarding ISs without question? In fact, to incorporate ISs into PTC functionality is not a regulatory requirement of PTC. Additionally, not only does incorporating ISs into PTC not provide any true advantage, but one could argue that to monitor ISs could become more of a hazard than a benefit, as well as a source for decreased velocity, due to the increase likelihood of false enforcements.

Note: the issue of false enforcements is primarily due to the significant variance in determining the braking curve necessary for enforcement, thereby possibly enforcing the train to a stop when it fact the operator could have managed to handle the train properly.

So, why have ISs been incorporated into the PTC platform? It all stems back, in my opinion, to one individual at one Class I who took the dark territory solution for PTC for which I was the architect at CSX, and put a non-pragmatic signal territory spin on top of it. However, it may go deeper than that it seems. Just as with the resistance that existed by Labor to reduce the trackage that requires PTC by 10,000 miles, as noted earlier, it seems that Labor has had its hands in the design of PTC as well.  I guess it comes down to jobs. In short, not only is PTC not a rationally justified safety system, but there is an irrational level of infrastructure being required to satisfy Labor.

I am not quite through as to reducing the use of WIU’s. I now look at point #3 as to the WIUs for control point. The point here is that the control points are already connected to the CAD platform via a wireless or wired pole line. These communication links provide the same data to CAD that are required by PTC. That means that WIUs are not required for control points either in that the code line infrastructure can be tapped by the PTC server at the back office to get the information required to generate targets. Wait, I am still not done with reducing the number of WIUs.

Consider point #2 as to ensuring no movement through a misaligned switch. This situation is somewhat similar to the approach I developed for handling work gangs and the Employee in Charge (EIC), which by the way is the approach being used for PTC by the freight railroads. That is, the on board PTC client notifies the operator of the train’s approach to a work gang and requests that s/he indicates via the on board PTC display whether or not s/he has approval provided by the EIC to proceed into the work zone. If no positive response is received by the PTC client within certain distance / speed / time parameters, then an enforcement is made. This same approach could be used to notify the operator of an upcoming switch and to request an input by the operator that s/he can verify that the switch is properly aligned. Again, as with the work gang, if a positive response is not received within a certain combination of distance / speed/ time, then an enforcement is made.  While this approach may seem a bit awkward, it is in fact a solution that is directly aligned with the operating rules.

Finally, as to point #1, the use of WIU’s for routing trains in dark territory. Actually, that one is still appropriate in that it was the solution I conceived for the development of PTC at CSX. As mentioned above, that PTC project was for dark territory and the other alternatives for routing trains at that time were too outlandish and/or too expensive, including the failed pursuit by the joint venture of GE and Harris to deploy Precision Train Control (not positive train control), a vital, moving block operation.

One last thought here. If indeed the railroads were to greatly reduce the number of WIUs based upon the above, then the cost of the wireless network would be significantly reduced as well, me thinks.

I await your comments.