In the previous 2 posts of this set of 3 regarding Industry INTRAoperability (not Railroad INTERoperability for PTC) I addressed both the opportunity and the rail executive education that are required for the unprecedented opportunity to advance the railroads’ operations, both individually and as an industry. The underlying logic is that rail executives are motivated by their bonus plans to optimize the handling of their responsibilities. Hence, a strategic perspective that is beyond the horizon of their bonus program requires that top management be so educated to provide the incentive to think strategically as to the deployment of technologies to satisfy a strategic business plan, a.k.a. Strategic Railroading™. In this posting I discuss a well-proven process that provides the structure to do so.
In other postings on this blog I have referenced IBM’s efforts in the 70s and 80s to introduce the usage of computers across industries to replace manual business processes as well as to re-engineer business processes given the integration of computers with telecommunications, thereby establishing new flows of information within and between enterprises. In addition to the prestigious executive sessions that IBM provided for its clients back then, IBM developed a very formal process for identifying the information flow architecture that would support the advancement of computers. Referred to as Business System Processing (BSP), the Wikipedia description properly identifies the primary objectives, i.e.,
- understand the issues and opportunities with the current applications and technical architecture,
- develop a future state and migration path for the technology that supports the enterprise,
- provide business executives with a direction and decision making framework for IT capital expenditures,
- provide information system (IS) with a blueprint for development.
Why BSP can be of great value to the railroads in particular at this point is the opportunity of developing “a future state and migration path” given the proliferation of wireless networks, both private and commercial. Even more to the point is the tremendous effort and investment that the railroads are making to lay in a 220 MHz network in the name of PTC. And, as noted in other postings on this blog, this decision by the railroads to deploy 220 MHz is really pathetic in two primary ways. First, the railroads have failed to justify the need for additional 220 MHz as evidenced by FCC’s rejection of the railroads’ request for such spectrum in addition to what they already own. Second, there is no strategic business plan associated with any strategic technology plan (other than to just install 220 MHz) to cost-effectively use all of the spectrum that the railroads now possess. It is in support of both of these points that a BSP could lay the foundation of how wireless can benefit not only the individual railroads, but also the industry overall. In fact, had the railroads already performed a BSP for the industry, one that was truly understood and accepted by senior management, then the 220 MHz sham by the railroads’ technicians would have never gained any ground in my opinion.
So! It’s agreed then. A BSP can be greatly beneficial. But how is such a process performed?
There are 8 primary, structured & well-proven steps in performing a BSP, as follows:
1. Gain Executive Authority: This is often the most critical part of a BSP. Without the proper level of commitment to support the need for incorporating multiple departments of an organization within the study, the effort will fail with the first major disagreement between the departments, a disagreement that is inevitable;
2. Define the Business Strategy: This steps sounds difficult perhaps, but it actually is quite simple if the participants can be honest about the successes and failings of the organization and their individual departments;
3.Define the Business Processes: This is the most creative part of the BSP in that it requires visionaries that can look beyond the current processes and recognize the possible changes due to advancing technologies. For railroads it is the focus on wireless data that can provide for more timely and accurate management of the vast sets of mobile assets;
4. Define the Business Classes: Defining data classes (aggregates of related data elements) is very straightforward once the business processes have been defined. (Note the very simplified example below of which business processes create / use the various business classes.);
5. Validate Finds with Management: This process establishes a line in sand with the management team that demonstrates the study is meeting the objectives of the study so as to ensure on-going commitment.
6. Define the Information Architecture: Ah Yes! This is the most fantastic step where the BSP effort really clicks and all participants and management can see what they have been missing as to information flow between the primary entities, and processes. (Note below a simplified example of a BSP that I performed for the intermodal industry. The arrows indicate the flow of specific data classes (descriptions not included) between operational entities and/or data bases. The black objects and arrows are current, the red objects and arrows are new relative to the changes in the business processes, and blue objects are hardware that need to be developed;
7. Establish Information System Priorities: The appropriateness and credibility of the information architecture developed via the BSP is first tested here as each player pulls for particular interests in establishing the priorities of the future information systems. Using the above diagram as an example, the order in which the red blocks are developed, either individually or collectively, can greatly affect the actual success of reaching the desired overall objective.
8. Make the Business Case for Management: YES! The most important business case. If nothing else, the BSP process takes the control of technology investment out of the hands of the technicians who seemingly have the desire to deliver the optimum system as to capability, whether it is required or not. Again, the most current, and capital-wasting example of this is that of PTC deployment where the technologists are out of control as to wireless (220 MHz), a train positioning platform, and the use of wayside interface units to interface with Intermediary Signals ( see the previous posting on this block “IS … Not”).
Voila! I have managed or participated in 4 BSPs … and this is really good stuff.
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
This is the 2nd of 3 postings that address Industry INTRAoperability (I/I), i.e. the development of systems that support the business interest of the entire rail industry, versus the advances in technologies and systems made by each individual railroad for its singular purposes. I/I is not the same as Railroad INTERoperability, as is required to deploy Positive Train Control (PTC) as a safety enhancement to the traffic control systems that provide for the integrity of movement operations. Rather, I/I addresses the business perspective of the advantages to the industry by the improved management of key resources subject to the interchange of trains between railroads. The assets that I am referring include the full array: track time, train crews, yards, locomotives, rolling stock, and shipments of high value and/or involving security issues.
Yes! I did state track time, train crews, and yards even those assets don’t cross borders. The reason for doing so is that the use of those assets increases in efficiency as the degree of scheduled operations increases . . . And, the ability of an individual railroad to run to scheduled operations is partially dependent upon the schedule reliability of the railroads with which it interconnects . . . And, since most railroads have yet to demonstrate their ability to run to schedule to a significant extent, contrary to their claims, then a valuable opportunity of pursuing I/I is that of providing timely data of train movements, both position and speed, across all interconnecting railroads so as line-ups can be adjusted in a timely fashion. Unfortunately, even with such data, a number of roads are incapable of using it to any great extent given their lack of Proactive Traffic Management techniques that I introduced 6 years or so ago in my quarterly publication, Full Spectrum. However, it is encouraging that at least NS and BNSF have made such advancements via the deployment of pragmatic wireless solutions that can report the speed and position of their own trains on their respective properties.
As to the locomotives, rolling stock, and shipments that do cross railroad borders I identified a number of I/I applications 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). As the result of that study, I decided shortly thereafter to take the same approach that IBM used in the 60s and 70s to bring about major changes in the traditional business processes of a full range of industries with the introduction of main frame computers. That is, IBM established major executive education facilities and curriculums across the U.S. to expose their prospective clients’ top management teams to what could be done with computers. As noted in the previous posting, the initial efforts focused on replacing manual data handling processes, e.g., payroll, accounts receivables / payables, with computerized data processing. However, with the introduction of affordable disk storage and the integration of telecommunications with computers, the curriculums expanded in scope by identifying how to change the traditional business processes given the opportunities to rethink the flow of information within and between enterprises (The process of structuring a strategic information flow architecture will be discussed in the next posting: It Takes an Industry: Process).
So, following IBM’s lead I put together an Strategic Railroading Symposium for top railroad executives that would be sponsored by the supplier community overall to remove even the perception of bias. The symposium schedule (presented below) that I put together consisted of 2 tracks, Operations & Engineering, with two categories of topics each, that addressed I/I opportunities as well as other possible applications that I believed at that time would be valuable exposure for railroad top management. Actually, this effort was progressing well with the expression of key suppliers to participate . . . that is until the ramifications of the just-ordered PTC mandate took effect. At that point, rail’s management teams withdrew into their caves rejecting the consideration of anything other than the challenges of implementing PTC. The suppliers, hence, backed away from the opportunity given their inability to market even their current products and services, yet alone the challenges and risks of developing a long-term strategic perspective.
As you will see in the agenda below, several of those applications have had sporadic initiations across the industry in the last several years.
|Delivering Proactive Traffic Management NOW without new CAD|
|The pragmatic application of meet/pass planning tools|
|Effective management of the line-up|
|The challenges and opportunities of effective interchange|
|The challenges to increasing scheduled operations|
|Reconciling the perspectives of Service Design vs. Operations|
|Integration of yard status with main line dispatching|
|Minimizing conflict between high speed passenger and freight trains|
|Optimizing crew management relative to the lineup|
|Balancing locomotive fleets across the industry|
|Industry tracking of key rolling stock and shipment status|
|A new look at work order reporting in light of TSA requirements|
|Maintaining chain-of-custody for critical shipments|
|Opportunities for improved yard management|
|Track & Wayside|
|Unattended, locomotive-borne track inspection|
|Enhanced safety for on-track workers without authorities|
|Enhanced safety for workers within work zones|
|Monitoring the position and health of critical maintenance equipment|
|Locomotive tracking & diagnostics across the industry|
|Performance-based locomotive maintenance|
|Industry-based locomotive maintenance|
|In-train monitoring systems of equipment and shipments|
When rail management surfaces from the PTC abyss, then perhaps there will be an opportunity to reconsider some version of the Strategic Railroading Symposium.
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.
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.
- 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)?
- 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.