Archive for the ‘Positive Train Control (PTC)’ Category
Based upon the study my team just completed in Egypt to evaluate the safety and efficiency of the Egyptian National Railways (ENR), I have posted a video on youtube, and is provided below, as to the design for a new traffic control, traffic management, and enforcement system. This system is referred to as Virtual CTC + Enforcement. It offers small to medium railroads across the globe, both freight and passenger, a cost-effective and pragmatic solution to delivering both efficient and safe railroading with enforcement capability that exceeds PTC, ETCS, and ATC. VCTC does not require either the extensive capital investment or extensive on-going maintenance of conventional or advanced traffic control systems.
Check it out!
Given my now–completed engagement in Egypt to design a new traffic control, traffic management, and enforcement system, titled Virtual CTC + Enforcement, for the majority of the Egyptian National Railways (ENR), I have an even increased appreciation of 2 primary GOODs of railroad operations in the U.S. that do not exist in Egypt and many other countries across the globe. First, U.S. railroads are privately-owned in a capitalistic society that promotes the investment in those operations based upon the bottom financial line, simply stated as optimizing the return on investment. Second, the Federal Railroad Administration (FRA) provides the regulatory oversight without which inscrutable railroad operators have and could tradeoff the bottom safety line for the financial one. This blend of regulated safety and fiduciary responsibility has well serviced the railroads and the public alike since the Staggers Act of 1980 that deregulated the railroad market. As such, I dare say that nearly every decision by the railroads is a financial one, including those that deal with safety issues alone and not operations. Arguably, however, there here have been several exceptions as is the case of BNSF’s pursuit of PTC.
For most railroads, PTC as an overlay system, was never seriously considered to be a pursuit given that the costs of deploying PTC far, far exceed the projected safety benefits. The first PTC system, CSX’s CBTM for which I was the architect, was pursued because its engineer was at fault in the 1996 Silver Spring, MD accident in which there were 11 fatalities. Especially given the accident’s location within the DC Beltway, CSX feared that Feds would force some type of driver-enforcement system, and the only system being tested at that time was a pathetically over-designed concept referred to as Precision Train Control. This PTC was not an overlay, enforcement-only concept. This PTC was an overly ambitious and, at the time, technically-unachievable moving block concept. Hence, CSX’s decision was a defensive one to develop a pragmatic approach, and that I did with CBTM providing the foundation for the overlay PTC systems being pursued to meet the Federal mandate. Subsequent to CSX’s efforts, BNSF expanded on CBTM’s scope of dark territory to include signaled territory, and it did so because “it was the right thing to do!” according to one BNSF top executive. There did not seem to be any immediate financial justification for BNSF’s efforts . . . except for a possible hidden agenda to move to one-man crews at some point. Nonetheless, BNSF had seemingly made a too-rare decision to invest in safety for safety sake without the immediate financial justification.
The other railroads were clearly not following the leads of CSX and BNSF. The business case was clearly not there to make such a financial investment. However, those individuals and organizations that wanted PTC at any cost promoted analyses and statements about the business benefits of improved asset management (e.g., track time, capacity, locomotives, crews) that PTC could reportedly provide so as to falsely justify their position. These individuals and organizations were without the willingness, perhaps intelligence, to understand the difference between traffic control and enforcement. Simply explained, traffic control generates movement authorities and therefore is the means of achieving asset management effectiveness. PTC only uses the parameters of the authorities generated to provide enforcement. With the simplest of understanding and rational thinking, one will realize that it is the ability of a locomotive to reports its position AND speed that supports more effective generation of movement authorities, which determines the management of railroad’s assets. To provide locomotive position and speed data simply requires a wireless data path, which happens to be a requirement of PTC as well. But, a railroad does not need PTC to get the wireless data path, as readily demonstrated recently by several Class Is that are obtaining those alleged PTC business benefits without PTC. Nonetheless, after very credible reports from both private and government entities that belie the existence of PTC business benefits, there are still lingering comments that surface occasionally claiming the business benefits of PTC. For example, it has only been in the last year that the FRA finally removed such fatuous statements from its Website.
The net of the above is that BNSF initiated and continued its pursuit of PTC for altruistic reasons, it seems, while CSX did so to prevent a mandate of an overly expensive, if even achievable, enforcement solution. But that truly was it for the industry until the end of 2008 even though were occasional meetings of AAR technical committees with purported PTC interests.
Even with the regulatory processes in the U.S. for primary industries such as the railroads, the Congress can bypass the regulators and create laws without consideration of the bottom line of the corporations affected. Such is the case with the Railroad Safety Improvement Act of 2008 (RSIA) that was a knee-jerk reaction in less than 2 months following the horrific Metrolink / UP collision in September of that year that resulted in 25 fatalities. This Act mandated the implementation of PTC across major segments of freight and passenger operations.
So! What do the various parties do when 1. They (the Feds) want something at any cost, a cost that they don’t have to pay … or … 2. They (the RRs) are being forced to make very substantial investments in systems that are not cost justified, but are mandated to do so for the sake of zero tolerance for unsafe operations. Simply stated, “What price safety?” … and “Who pays the tab?” This is where it gets ugly.
When so confronted with Congressional mandates, a company has the choice to pay the price, pull up stakes, fight the action through the courts, …. and / or ….. to delay, lie, misdirect, fake it, and/or use lobbyists to influence the Congress to amend such mandates in some fashion. In the case of the PTC mandate of RSIA, those railroads other than BNSF, and possibly CSX, have clearly demonstrated an amazing amount misdirection, faking it, if not just outright lying, to obtain at least delays in the PTC mandate. The high mark of this activity to date was the NTSB conference on PTC, February 27, 2013. I did not attend the conference, but I have reviewed the presentations of the various speakers, and provide below my perspective on both the credible and irresponsible, if not mischievous, points that were made.
Having been involved with PTC from the beginning, even before the FRA RSAC-PTC process a decade or so ago, I know most of the presenting individuals very well and could “hear” their oratory as I reviewed the decks. Hence, I was not surprised by most of the points made, but yet saddened and angered at what the railroaders find necessary to do to attempt to avoid the unjustifiable expense of PTC. Simply stated, they seemed obligated for their company’s sake (if not their job) to purposely mislead, misrepresent, and even lie about critical points that they believed would helpful in delaying the implementation of PTC and its tremendous capital outlay. At the same time, I was surprised and gladdened by some of the reversals in falsehoods that had been made by railroaders following the mandate. Below, I summarize and separate the uglies and the reversals into 4 categories of PTC Functionality, and the primary technologies that are involved with PTC and other primary applications associated with a railroad’s operations: Communications, Intelligence Processing, and Positioning.
- One presenter, at least, noted that PTC is much more complicated than anyone expected. However, its not PTC that is complicated, but rather it is a combination of Interoperabitity and the over-engineered communication, positioning, and intelligence processing solutions that ITC has been developing unchecked by senior management as to costs per necessary objectives (as discussed further below).
- Again, as discussed above, PTC has nothing to do with asset management and the associated business benefits (other than preventing occasional disruptions due to accidents).
- The various forms of “vital” have been used in confusing ways across the industry in addressing PTC. In the early days of RSAC-PTC I introduced the concept of functional vitality to separate the purpose of PTC from that of traffic control systems, e.g., signaling, dark territory. To be short, PTC is not functionally vital in that it does not generate authorities. Nor does the PTC BOS need to be a vital, fail-safe system, with I refer to as hardware vitality. There is an argument, however, for making a fail-safe on-board system so as to minimize the occurrences of traffic congestion as a train limps to the next yard due to regulated speed restrictions due to non-working PTC systems.
- The comparison of PTC to European ERTMS / ETCS is totally inappropriate and purposely misleading. ERTMS is an integrated traffic control/ traffic management/ and enforcement system designed for high speed / high density traffic. PTC is an overlay system, meaning that it acts independently of the traffic control / management systems already in place. Hence, the complexity, costs, and timeliness of implementing ERTMS, which is functionally vital, provides NO points of comparison for overlay, non-functional vital PTC.
- A PTC-reliability study performed by ARINC was mentioned as a point of concern. Really! ARINC has a tremendous potential conflict of interest with the railroads and is clearly not in a position to be declared objective.
- Two years ago I was the Chairman of the first World PTC Congress. During that meeting I challenged the attendees, including FRA, suppliers, and Class I railroads to explain why it was necessary, or just important, to monitor and enforce intermediate signals. No one has ever stepped up to that question other than retired FRA employees who stated it clearly wasn’t necessary. Of course, it isn’t necessary since PTC provides a braking curve to the end of the authority. Nonetheless, the railroads have added this significant complexity, and associated cost of additional WIUs, to meet this unnecessary requirement. Originally, the first estimate for WIUs following the mandate was 75,000. It’s now down to 35,000, and I’m pushing for 20,000 at the most.
- Early on in the RSAC-PTC process it was agreed that grade crossings should not be an enforcement objective. The reason was two-fold. First, it’s the railroad property and therefore they should not have to pay for the necessary infrastructure. Second, and arguably most important, the pure physics of bringing a freight train to a stop would mean an excessive amount of gate down time, thereby possibly increasing the risks of vehicles running around the gates.
- Contrary to what was noted by several presenters, it is clear that there was no true analysis of the data requirements for PTC for the railroads to make an actual evaluation of the need for 220, especially over that of 160. This is admitted to in the filings by PTC-220 with the FCC, and as identified (and not contested by PTC-220) in my written statements to the FCC regarding the same filing. Both my statements and those of PTC-220 in its filing for more 220 spectrum are available upon request to me. When last checked, the FCC had rejected PTC-220’s request. On a positive note, the presentation by NS regarding PTC-220 was refreshingly honest compared to those statements and filings under the previous UP presidency of that entity. The individual noted that there is no expected need for additional 220 spectrum for most of the railroad operations.
- As to why 160 was not considered by the railroads for PTC has little to nothing to do with the amount of spectrum available. Rather it has to do with the way in which the railroads proceeded to meet a FCC requirement to “narrowband” the frequency. To be short, they pursued conventional channel assignments instead of using “trunking” which is critical for effective usage of the spectrum in metropolitan areas.
- It should be noted that UP / NS purchased the 220 spectrum the year before the PTC mandate – before the MetroLink/UP accident. Why they purchased the spectrum is unclear, but given their resistance to voluntarily pursuing PTC, it is doubtful that they did it for PTC. It was after the mandate that BNSF and CSX were “persuaded” to forego their own communication solutions for PTC, each of which was much less robust, yet adequate, then the required wireless claims stated without proof by PTC-220. Subsequently, PTC-220 purchased Meteorcomm from BNSF to produce the locomotive radios even though Meteorcomm had neither the proven technical nor available manufacturing capabilities to provide the radios.
- The Back Office Server (BOS) was suggested to be a portion of the critical path to meet the deadline. In my opinion there are 3 possibilities that this could be, with only one that makes any sense at this point. First, the functionality of the BOS is very, very straightforward and has already been achieved by BNSF with some minor changes remaining due to changes in the operating rules to address interoperability, as agreed to by the railroads during the conference. Second, the concept of vitality, as to failing safe, is clearly a red hearing. An overlay system can hardly fail other than safe in that it doesn’t generate authorities and instead only targets based upon the authorities generated. Even more misleading, one presenter likened the vitality of the BOS to the vitality of the European ERTMS. This is a purposeful misdirection. The vitality of ERTMS is that of the generation of authorities and the integration of the enforcement processes. PTC is an overlay only and the functional vitality of generating authorities does not exist. Only the third reason has any merit. That is, linking the BOS with the individual Traffic Control systems in place for each railroad could be difficult. This is not due to technical reasons, but due to social/political conflicts that may exist between any given railroad and the suppliers involved, most importantly Ansaldo, formerly Union Switch & Signal. While Wabtec’s and Ansaldo’s HQs are only miles apart in Pittsburgh, their mindsets and willingness to cooperate between themselves and the railroads involved could span oceans, if you will.
- PTC is locomotive-centric, meaning that all processing of data for enforcement takes place within the on-board computer. Normally, this would not need to be stated, but the fact that the conference included a presentation on ARES suggests that someone thought there was some value in understanding the pursuit and the ultimate rejection of ARES. To be clear, ARES was a clever traffic control and traffic management concept that integrated some PTC-like enforcement capability in the back office systems for signaled territory. However, it really has nothing to do with locomotive-centric, overlay PTC systems that are designed for both dark and signaled operations. CBTM established the threshold for PTC, and the Singularly Disillusioned individual (SD) that has been inappropriately promoting both the supposed vitality and business benefits of PTC based upon his ARES experiences has actually done some harm in advancing PTC in a credible fashion, as exemplified by the horrendous FRA-funded report on PTC benefits performed by ZetaTech several years ago.
- I didn’t note any significant comments regarding the issues of positioning, other than those of SD in the ARES presentation. Again, his comments are way out of fashion as to his focus on DGPS, as well as the fact that it was in my designing of CBTM that I introduced the monitoring of switch position in dark territory for “routing” trains, and which subsequently became relevant for the 4th objective of PTC of preventing movement through misaligned switches.
- From my previous evaluation of ITC activities for a client, it became clear that the ITC technicians were way over-designing the accuracy of the positioning platform – I mean way, way overdesigning. The major effect of this is excessive cost for the on-board platform that could be in the range of $10,000 to $20,000 per locomotive, hence raising the cost of nation-wide PTC by several $100 millions
I would like to think that the NTSB recognizes that a number of presentations made at the conference to support an extended implementation period were highly prejudiced and even purposely misleading in some cases. Fortunately, PTC is beyond the need to evaluate the feasibility of its functional capabilities. PTC does work. The primary constraints that are being presented by the railroads are a technical nature, as noted above. Hence, if NTSB requires an objective analysis of PTC implementation issues, it requires a Blue-Ribbon Technical Committee, independent of the FRA, the railroads, and the likely suppliers, that can make such evaluations. The railroads will likely object to such evaluations. But, cannot any extension in time for the mandate be made conditional on such evaluations?
Outside of North America
For those railroads outside of North America that may be considering some type of enforcement system, e.g., V-CTC + Enforcement in Egypt, the above discussion as to the cost / benefit analysis of PTC does not likely apply. For example, the V-CTC + Enforcement system that I designed will prevent accidents due to mechanical interlocking operators and level crossing guards. In fact, my presentation of the final system design of V-CTC + Enforcement to Egypt’s MOT / ENR officials in December, 2012 was delayed several weeks due to two accidents, one each regarding the interlocking operator and crossing guard, that resulted in 5 and 50 fatalities respectively. V-CTC + Enforcement would have prevented those accidents; PTC as designed for the U.S. would not. Accordingly, Egypt’s Prime Minister directed MOT / ENR the following day to proceed with testing V-CTC + Enforcement.
I played a decent amount of basketball in my high school years. However, being 6’3” was not enough by itself to compensate for my lousy shooting. And, I wasn’t a good shot because I was unwilling to practice enouigh to build that “muscle memory” of the physics associated with putting the ball in the hoop. Therefore, I spent my court time mastering the interception of passes between the opposing team players by anticipating their moves. I was really good at “reading” their intentions in the passing of the ball. My skill, it seems, was a combination of perception and the ability to fake where my attention was in the other team’s handling of the ball. My strategy was if I could intercept their passes, then I could pass the ball to my team members who could make the shots. The point here is that there are those individuals that grab the ball, and there are those that can make the points once they have the ball. This is one ideal “team” perspective in my opinion given so very few individuals can do both. Unfortunately, in the U.S. railroads today, those who have the responsibility for obtaining the ball also have the responsibility for taking the shots – and they really suck at shooting. I am referring to the railroads’ technicians and their free-hand at designing and installing technologies without responsible upper management oversight. Simply stated: I think there is a great deal of faking going on in railroad management, whether it be intentional or just the nature of the organization.
Is there any doubt that there are times that each of us fakes it personally and professionally . . . but not necessarily for the wrong reasons? That is, we present viewpoints and take on tasks that are beyond our actual knowledge and skill set with the expectation (based upon past experiences) that we will succeed … and with the hope that our audience won’t be able to contest us either due to their lack of on-point knowledge or their lack of intestinal fortitude to take on the “authority”. Unfortunately, however, in the railroads I see faking-it to be a two way street between the technical and operational managers that is resulting in a horrific waste of capital and, in the case of wireless, the waste of valuable RF spectrum. That is, the technicians fake that they have done their due diligence in promoting that there technical solutions are absolutely the most cost-effective . . . and the operators feign (or worse don’t even participate) that they have done their due diligence in challenging and understanding what they are offered by the technicians. While I am sure that there are some excellent examples where it is clear the technicians and the operators have worked together to deliver cost-effective technical solutions, there are too many examples where they have not. Arguably, the most egregious is that of the ITC efforts to address the interoperability challenges of PTC. There are 3 primary examples.
- I have already exposed in this blog as well my articles in Railway Age, and my submissions to the FCC, that the grab for more and more 220 MHz by the Class Is is an intentional scam (IMHO). This is faking-it taken to an unprecedented level for the industry because it is not a single railroad that is the perpetrator, but rather a class(1)action, if you will.
- Having spoken recently with a supplier of NXDN, a digital wireless protocol, I am of the opinion that the availability of the significant increase in channels by narrowbanding VHF has afforded the railroad technicians the opportunity to once again forego their responsibility of using at least the 160 MHz band in a good-citizen, yet cost-effective fashion.
- As to positioning accuracy for PTC, the technicians are striving for levels of accuracy that are far, very far, exceed that which is really necessary due to their inability to understand what is really required, and rather to ensure that they will never be at fault regardless of the cost.
Fortunately, there are several railroads that don’t buy into these fatuous technology activities and recognize that there are solutions that are much more cost-effective. It would seem that these railroads have a team perspective of obtaining the ball and making the shot. But unfortunately for too many railroads, there is a lack of upper-management understanding and support for doing the right thing for the right reason. That is, for too many railroads the exploits of technologies by technicians goes unchallenged by the management teams that have the responsibility for their railroad’s bottom line, with or without consideration of what makes sense for a country with constrained RF capacity.
THE bottom line is that the technicians are in fact faking it as to providing technology-based solutions that are grounded in responsible economics. They are doing so because, IMHO, 1. they believe that it is their responsibility to provide the best (most complex) technology regardless of the cost and regardless of whether or not such complexity is required, and 2, railroad management has failed to get involved in understanding the business perspective of technology decisions. So! Who is at fault? In my opinion, it is the RRs’ senior management failure in developing a business strategy in sync with a technology strategy that has set up the situation. Could the focus on the current year’s bonus plan have anything to do with this? Hmmmm!
So! I ask you: When you fake it, are you doing so for the right reasons? Are you avoiding the critical issues important to your organization so as to “kiss up” to your management or to your annual bonus, whether you work for a railroad or a supplier? . . . or . . . Are you realistic as to what can be achieved and willing to speak up? . . . or . . . Do you really care one way or the other? As an independent consultant I don’t fake it with my clients. They will get both a short-term tactical and a long-term strategic perspective whether they want it or not. I will grab them the ball, but they have to make the shot.
With the introduction of overlay PTC just over a decade ago, the concept of vitality needed to be expanded at that point beyond the mantra of signaling engineers as to a vital component or system being one that fails in a safe manner, i.e., failure without introducing any additional risk. In addition to this design vitality, it was necessary to introduce a concept of functional vitality to prove that PTC was and remains not vital. That is, a functionally vital entity is one that generates the movement authorities for trains, thereby providing for the integrity of train movements. For signal engineers the two concepts are inseparable, and in their viewpoint, anything associated with traffic control must by vital. Such fatuous rationalization can be quite unfortunate for the deployment of advancing technologies in railroads, including PTC. Two current examples here are ITC’s efforts in designing the wireless and positioning platforms for PTC that are way beyond what is required for a non-vital system, if even a vital one.
In anticipation of such design tangents by railroad technicians ( as demonstrated in the past by UP with it Precision Train Control project that died from overdesign), I introduced the functionally vital perspective a decade ago to demonstrate that overlay PTC is not vital and therefore not subject to the design and regulatory complexities associated with vital systems. Stated otherwise, PTC’s ability to enhance the safety of rail operations is substantially less critical than that of the traffic control systems that provide for the integrity of train movements. PTC only addresses human errors whereas traffic control systems are absolute.
Being the architect of the first overlay PTC system, I was continuously challenged during the early years by labor, FRA, suppliers, and even my counterparts on other railroads, to explain why PTC is not vital. The forum for these discussions was primarily that of the Rail Safety Advisory Committee (RSAC) for PTC that was charged with defining the core objectives of PTC. Understandably, RSAC-PTC was primarily manned by signal engineers who live and breathe vitality with their natural inclination being that everything is vital. Again, for them PTC had to be vital, I assume, because it addresses safety, and it is related to vital traffic control systems. At the same time, signal engineers when asked during the courses I teach on PTC and railroad operations “What is vital in dark territory?”, will respond that there is nothing vital since there is no wayside equipment. The solution for addressing both of these ill-structured mind-sets of signal engineers as to PTC and dark territory was to provide the functional definition of vitality that really goes to the core of running a safe railroad, i.e., the generation of authorities.
In parallel with the functional vitality effort was the extraordinary task of convincing the masses that PTC did not deliver those business benefits that continue to be so widely and wildly proclaimed by FRA and suppliers as to increasing traffic density and the efficiency of the key operating assets, e.g., crews, locomotives, and even maintenance crews. I quote the FRA’s website “In addition to providing a greater level of safety and security, PTC systems also enable a railroad to run scheduled operations and provide improved running time, greater running time reliability, higher asset utilization, and greater track capacity.” Here is the simple, and one would think very obvious, logic as to why overlay PTC can’t provide such business benefits. To increase traffic density means that the generation of movement authorities need to be done more efficiently … and since PTC does not generate movement authorities (nor deliver them as the FRA website proclaims – that is the purpose of digital authorities – not PTC), then it cannot provide those benefits. Actually, if not properly designed, PTC can actually decrease both the traffic density and safety by making unnecessary enforcements. What the FRA and others who flaunt PTC business benefits refuse to understand is that it is the wireless data path required by PTC that also permits train tracking status data to be delivered to back office management systems. As demonstrated by NS and BNSF at least, a railroad doesn’t need PTC to obtain the stated business benefits; a railroad only needs a wireless data platform, whether it be cellular, satellite, and/or private. In any event, the bottom line remains, i.e., PTC is not vital in any sense.
OK, at this point you may be thinking about VPTC (where V means vital) which is one title given to the PTC systems being pursued by the freight and commuter railroads. Clearly such a title suggests that PTC is vital, but it isn’t. VPTC means that the platforms upon which those PTC systems are deployed are design vital so as to reduce the failure of the PTC system, but PTC is still not functionally vital. The purpose of VPTC is to provide a pragmatic economical solution to regulatory issues that requires a restricted speed for a train should its PTC platform fail. In heavy density corridors, the application of restricted speed could result in significant business costs.
With the distinction between design and functional vitality now established above, I introduce a new vitality phrase: “Vital Employee”. Simply stated, a vital employee is one that generates a movement authority. For U.S. railroads, the primary example is the Employee-In-Charge (EIC) that provides the authority to a train to move through a work zone, a work zone that is encapsulated (nested) within an authority generated by a traffic control system. Handling the enforcement of the nested EIC authority was a major design issue that I had to provide for the first overlay PTC system … and is now used by the PTC systems being deployed by the freight railroads. Again this was done in a non-vital way by not affecting the underlying Method of Operations, thereby avoiding regulatory complexities.
The vital employee perspective has proven to be particularly challenging in my assignment as Project Leader for a consulting effort in Egypt to advance both the safety and efficiency of the majority of the Egyptian National Railways (ENR) operations that use token block and TYER, a.k.a. British Absolute Block, traffic control systems. In the case of ENR, their operations have mechanical interlockings that are handled by operators independent of the central movement office. Instead of a centralized dispatcher, ENR uses block/interlocking operators to generate block-by-block authorities thereby compromising the efficiency and safety of train movements compared to that which railroads around the world achieve with dark and signaled operations. For this engagement, a “virtual” CTC (V-CTC) system is being designed that will provide for multiple block authorities subjected to nested, manual interlocking authorities. This solution provides for enforcement for the authorities generated by both V-CTC as well as the interlocking operator.
As a closing point, I wish to remind all that the Book of Rules provides the underlying threshold of vitality for all rail systems. In my 40+ years in the industry, I find that too many tend to ignore this point – just as signal engineers tend to ignore dark territory.
In the forthcoming April, 2012 issue of Railway Age, I expose the tremendous over-design of PTC by the railroad’s technicians. Specifically I refer to the issues of 220 MHz for a wireless network that is totally unjustified given the railroads current available wireless bands that are being ignored (which the FCC shot down as to the request for additional 220 spectrum), as well as their pursuit of a Positive Train Location (PTL) component that is far beyond that which is really required. What I purposely left out of the article was the railroads’ pursuit of incorporating Intermediary Signals (ISs) into the functionality of PTC. I did so because I thought this was a bridge too far for even Railway Age (what I consider to be the most daring and honest of railroad periodicals) to take on this subject. But, the short is that the railroads’ technicians have once again ignored the actual requirements by developing solutions that are, again, totally unjustified as to both functional and technical perspectives. If you dig deeply enough into this blog you will find a posting YOY WIUs where I introduced my thoughts with an explanation meant for the non-technicians. What you read below, is a well-qualified operator’s perspective of this very point. The author is Dave Schanoes and his blog is www.ten90solutions.com.
PTC–Everybody, at least in the US, is talking about PTC. I’m no different. I talk about it. I think about it. I do some work on it. And let’s be clear– I welcomed the mandate for it… although let’s be completely clear: the Chatsworth collision that moved the US Congress to act could have been prevented by the decades old cab signal/ATC systems in use on many railroads.
So maybe PTC wasn’t needed there, but even with ATC something more is needed; actually a few something mores, given the mixture of signalled and non-signalled territory in the US.
I was talking to my friend, Ron Lindsey, of Communication Architecture about end of train, restricted speed, intermediate signals and his questions made me think, and my thoughts made him question me some more, and we agree on this:
Why This? And why not This?
March 26, 2012
236.1005 (a) (2) of the famous subpart I of the regulations governing train control reads:
“[Each PTC system required to be installed under this subpart shall] include safety-critical integration of all authorities and indications of a wayside or cab signal system, or other similar appliance, method, device, or system of equivalent safety, in a manner by which the PTC system shall provide associated warning and enforcement to the extent, and except as, described and justified in the FRA approved PTCDEP or PTCSP…”
which means, or has been interpreted to mean, intermediate block signal indications of a fixed block system, utilizing either wayside or cab signals or both, must be displayed [that’s the authority part, because in rule 251 or 261 territory, signal indications are the authority for movement] and enforced [that’s the indications part, as the fixed wayside, or cab displayed, block signals are speed indications].
There’s a “limited cab” in your system that means passenger trains must not exceed 45 mph? Guess what? PTC has to display and enforce that limited cab and speed.
So here’s my question…”why?” I’m serious, why? What is gained by PTC enforcing the intermediate signals rather than calculating the braking curve and enforcing the braking curve to the point of restriction?
Well, someone’s going to say, because the point of restriction is a train somewhere ahead of the train receiving the “limited” indication, and the point of restriction is the restriced speed indication protecting the block in which that train is, and any block signal can be a signal displaying restricted speed, and therefore, PTC must monitor the intermediate signal aspects and enforce the intermediate signal indications.
Before we go any further– no, I’m not going to advocate we do away with fixed blocks [although I heartily recommend doing away with wayside signals except at interlockings in favor of cab signal systems. And no, I’m not going to make an argument for CBTC or dynamic block or moving block, because I do not think CBTC or its variants are required for either passenger or freight movements in the US, given the density of the traffic. And, no I’m not going to advocate doing away with the “restricted speed” indication— I think the restricted speed indication has a very important role to play in terminals, yards, stations, and for broken rail protection.
I just don’t think “restricted speed” (1) can actually be enforced by PTC (2) is an effective and “positive” method of safe train separation.
Far be it from me to opportunistically cite the recent spate of restricted speed collisions as supporting evidence, but I refer to the recent spate of restricted speed collisions as establishing the point that we need to do just a bit better.
First, enforcing intermediate signal indications, even the restricted speed indication, is not necessary to PTC accomplishing its core functions: preventing train-to-train collision; derailment due to overspeed through permanent or temporary speed restriction; unauthorized incursion into a work zone; operation through a switch not properly lined for the train’s intended route.
Train-to-train collisions can still occur at restricted speed; overspeed derailment can, and is prevented without resorting to signal indication; unauthorized incursion into a work zone is eliminated through enforcement of a positive stop ; an improperly lined switch should also be protected through enforcement of a positive stop.
And… PTC is not enforcing restricted speed. It is only enforcing the numerical magnitude, the “not to exceed,” tacked on to the rear end of the definitiion. The meaning of restricted speed does not reside in the speed value. The authorization for continued movement upon receiving the restricted speed signal is not an authorization to proceed at a certain speed. The authority for movement is based on crew responsibility, upon the crew observing the rule. Of course, this simply reintroduces the possibility for human error, which PTC is supposed to prevent in the first place.
The “guts” of the restricted speed indication is that “movement must be made at a speed that allows stopping within half the range of vision short of….” ( you know the rest). PTC can’t enforce that.
Would you like to know something else about intermediate signals and the enforcement of their indications? Railroads don’t do it. Cab signal/automatic speed control systems do not do it… or aren’t required to do it.
You wanna bet? Yeah, I wanna bet.
Back in the day when I was person with a bit of authority on a major commuter railroad in a major metropolitan area, I took out my trusty pencil and paper and did some calculations.
We used a 4 aspect, fixed block, cab signal/speed control system. The aspects and associated indications were: “normal”= MAS; “limited”= for passenger trains, not to exceed 45 mph; “medium”=for passenger trains, not to exceed 30 mph; “restricted”– prepared to stop within half the range of vision etc. etc. not to exceed 15 mph.
On a rather busy portion of our railroad, the MAS was 80 mph. A train receiving a downgrade to “limited cab” was theoretically required to be at limited speed before entering the next block, particularly if the signal indication at that block was “medium cab.”
With our four aspect system, our signal design distance for deceleration from 80 mph to zero was approximately 9600 feet. Our required rate of deceleration was 1.28 ft/sec/sec or (-).84 g.
But because we do things evenly, each block was approximately 2400 feet long. Our signal design distance showed a required distance for decelerating from 80 mph to limited speed [45 mph] of 4611 feet, including the 8 second free-run time.
So what gives, here? What gives is that our on-board speed control systems did not monitor the target speed of the train in accordance with the speed transmitted by the signal protecting that block, but by the required braking rate to achieve zero velocity.
Certainly, if the engineer released the brakes before the target speed was achieved, a penalty brake application would ensue, but that again was based on not achieving a required rate of deceleration.
PTC does that. It enforces that. What it needs is not the signal data per se, but the location of the speed restriction, the target to which it calculates and enforces the required braking curve to comply with the limit to authority.
Cab signal/ATC systems convey authority to the following train enforcing the numerical magnitude of the speed, rather than enforcing the limitation to the authority. And that limitation is strictly a function of the technology the signal systems were built upon.
Why restricted speed? Why intermediate signals? Because we had NO WAY of determining, in the field, by the field apparatus, the location of the rear end of the leading train.
And today? Today, we definitely have that technology. We have GPS to locate the head end of the train. On passenger trains, we know how many cars are in the consist and the exact length of each car.
And for freight trains? Freight trains in the US operate with EOTs– end-of-train devices that utilize radio telemetry to convey the brake pipe pressure, airflow, etc. at the very rear of the train to the head end of the train. There is no reason that signal cannot be enhanced, and processed to confirm train integrity to the GPS system and to measure train length.
Conveying the train length to the Back Office System and using that length to enforce a positive stop, to withdraw a following train’s authority for movement at a point to the rear, then becomes part of our algorithm, adjusting for grade (slack on the lead train, braking on the following) for safe train separation. This is not “moving block”– but certainly could become so in existing dark territory– but rather limit to the authority for movement in a fixed block system.
And if you ask me, it would be a shame to let the limitations of an older technology hobble that of the new, forcing us to repeat the same old, same old, same old failures.
You did ask me, right?
Copyright 3/26/2012 by Dave Schanoes
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:
- 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.
- 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.
- The awarded contractor, University of Southern California (USC), has no known experience in PTC, yet alone primary railroad operations, IMHO.
- 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.
- 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 firstname.lastname@example.org. 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 1st this year, will be addressing interchangeability in substantial detail as to the challenges and the opportunities.