Posts Tagged ‘PTC mandate’
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.