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As Time Goes By

The FRA concludes its analysis of the circumstances precipitating the EO with this statement:

The December 1 accident demonstrates that Metro-North's existing ATC system and other existing overspeed protections are not sufficient to prevent dangerous overspeed events.

As a consequence FRA ordered Metro-North to take certain extraordinary measures to reduce the risk of further overspeed incidents.

If Metro-North's ATC system and overspeed protections were not sufficient to prevent dangerous events, what about other railroads and their ATC systems, overspeed protections, or the lack thereof?

Those railroads received a safety advisory. FRA, having identified a danger to safe train operations that was industry-wide, required action only of one railroad.

On December 16, 2013, FRA issued Safety Advisory 2013-08:

FRA is issuing SafetyAdvisory 2013–08 to stress to railroads and their employees the importance of compliance with Federal regulations and applicable railroad operating rules regarding maximum authorized train speed limits and any relevant speed restrictions. This safety advisory contains five recommendations to railroads to ensure that compliance with authorized speeds and other speed restrictions are addressed by appropriate railroad operating policies and procedures and to ensure that those policies and procedures are effectively implemented.

The recommendations included this:

(4) Evaluate quarterly and 6-month reviews of operational testing data as required by 49 CFR 217.9. A railroad should consider increasing the frequency of operational testing where its reviews show any non-compliance with maximum authorized train speeds. A significant number of operational tests should be conducted on trains that are required to reduce speed by more than 20 mph from the maximum authorized train speed. Operational tests should use the reliable methods available, such as reviewing locomotive event recorder data and testing by radar to verify compliance with maximum authorized speeds.

FRA included a special bit of advice to railroads in this SA:

FRA intends to focus its inspections on railroad operational testing activity over the next several months on compliance with maximum authorized train speeds and relevant speed restrictions.

And where did that get us as time goes by? It got us all the way to Frankford Jct.

On May 21, 2015, in response to the overspeed derailment of Amtrak #188 at Frankford Jct, FRA issued EO 31, introducing it with the words that have become disturbingly familiar, like a dirge:

FRA has determined that public safety compels issuance of this EO....FRA has concluded that additional action is necessary in the form of this EO to eliminate an immediate hazard of death, personal injury, or significant harm to the environment.

Again having recognized a vulnerability that was industry-wide, FRA required action only on the part of a second single railroad. The rest of the industry got another safety advisory.

On June 9, 2015, FRA issued Safety Advisory 2015-03, focusing on the need for railroads to make additional efforts to reduce the risk of overspeed accidents. The purpose of SA 2015-03:

FRA is issuing Safety Advisory 2015-03 to stress to passenger railroads and railroads that host passenger service and their employees the importance of compliance with Federal regulations and applicable railroad rules governing applicable passenger train speed limits. This safety advisory makes recommendations to these railroads to ensure that compliance with applicable passenger train speed limits is addressed by appropriate railroad operating policies and procedures and signal systems.

Sound familiar? Unfortunately. Repetition in this case is the index to failure.

Among the recommendations is this one:

(5) If the railroad does not utilize an ATC, cab signal, or other signal system capable of providing warning and enforcement of applicable passenger train speed limits (or if a signal system modification would interfere with the implementation of PTC or is otherwise not viable) all passenger train movements at the identified locations be made with a second qualified crew member in the cab of the controlling locomotive, or with constant communication between the locomotive engineer and an additional qualified and designated crewmember in the body of the train. If the railroad is required to implement PTC at the identified locations, implement these recommended changes in the interim.

FRA included another bit of specific information in this safety advisory:

FRA will continue to focus on ensuring passenger railroad compliance with maximum authorized train speeds and relevant temporary and permanent speed restrictions in the coming months, including stepped up enforcement actions. These actions will include, but will not be limited to, on-board inspections, radar speed monitoring at locations of significant permanent or temporary speed restrictions, monitoring of railroad officers who conduct operational tests, and comprehensive reviews of a railroad’s implementation of their operational tests and inspection program.

Now I don't know if FRA actually did increase its review of operational testing on railroads for speed compliance. I don't know if FRA followed through on its on-board inspections, or radar speed monitoring. I do not know if any railroad other than Metro-North enhanced its speed control system to include enforcement of civil speed restrictions. And I'm not about to request that FRA provide a comparison, say, of the number of operational test reviews and speed tests it conducted in the 18 months between the derailment of MNR train 8808 and Amtrak 188, with the number of speed tests, and the number tests and reviews it conducted in the 30 months between the derailment of 188 and Amtrak 501. That would be regarded as an FOIA request, and I can't handle FRA's billing rates.

So where did that get us as time goes by? It got us coast to coast, from the overspeed in Hoboken terminal to the overspeed of Amtrak 501 in Washington.

I've learned a couple of things, despite my best efforts, during my time working on and for railroads (I had some good teachers, and what I haven't learned is no reflection on them).

I learned that for every problem on the railroad, there are in general, two types of solution. One solution is an operating solution-- an adjustment to the operation that contains the problem, but at the same time accommodates it; basically incorporating the risk into the everyday execution of the service plan. We have a 30 mph curve in a 75 mph section? We train the locomotive engineer. We put up permanent speed restriction signs. We require the crew to have a safety briefing before each run, discussing speed restrictions. We require two qualified persons in the cab. We require constant communication among the crew members.

At every point where we have mitigated the risk, we have at the same time compounded the opportunity for human error and human failure. That's the conundrum of, and the limits to, the operating solution.

We've done those same things throughout the history of railroading, waiting, in part, for technology to catch up. "Train orders must be read and understood by all those who are to execute them..." remember that one? Same principle.

As time has gone by, technology has more than caught up, and the inertia of established railroad practice, the inertia of a capital intensive (high fixed cost) operation makes the industry slow, if not flat out opposed, to the introduction of new technologies.

Now the other solution available is the engineering solution. The engineering solution is designed to eliminate the risk by either eliminating the physical conditions that create risk, or preventing the human error that converts risk into catastrophe.

We have a 30 mph curve in a 75 mph section? We physically reengineer the 30 mph curve; transforming it into a 60 mph curve. Or, we install a train control system capable of enforcing speeds determined by track geometry-- "civil speeds"--as well as those speeds required by safe train separation.

Now the operating solutions are cheap.......until they're not; until a train crew forgets what they were taught; forgets where they are; forgets the safety briefing; misses the approach speed restriction signs. Then you're paying out maybe $50 million, maybe $250 million to the survivors and families of those who didn't survive.

Then the $1 million per mile you figured for advanced automatic speed control, including interlockings, doesn't seem so expensive, does it?

To say the lines of authority and responsibilities for the construction, qualification, operation of the Point Defiance Bypass service were a bit blurry is to engage in understatement.

As near as I can tell Washington state purchased the line; Sound Transit (Sounder Commuter Rail) was the owner of the line. Washington State DOT Rail Division was the agency responsible for management and oversight of the project.

To that end, WaDOT contracted with Sound Transit to deliver the track and signal work necessary to rehabilitate the line and make it "fit" for passenger service. Sound Transit essentially operated as the construction manager for the project.

The project applied for and received a substantial portion of funding from a grant issued through the American Reinvestment and Recovery Act.

FRA? According to WaDOT, FRA took the lead in determining and ensuring satisfaction of the requirements of the National Environmental Policy Act (NEPA), reviewing the Environmental Impact Statements.

Also, FRA would have been responsible for monitoring the expenditure of the grant money.

Washington state DOT assembled a project technical advisory team made up of two representatives from WaDOT, representatives of three cities (where traffic would be affected by the new service at the rail-road grade crossings), a representative of the Federal Highway Administration, a county representative, a representative from a local school board, representatives from two military bases, and representatives from Sound Transit.

FRA? No mention of FRA representation on the technical advisory team.

Amtrak? Despite the statement that "the end result is more frequent, more reliable, and faster Amtrak Cascades service.....When completed, the Point Defiance Rail Bypass project will bring a total of six daily round trip Amtrak Cascades trains and one Coast Starlight train through Tacoma, Lakewood, and DuPont intersections, with an average crossing time of 45 seconds per intersection and a maximum speed of 79 mph," no Amtrak representative was included in the technical advisory group.

The project also organized an executive advisory team, again without including FRA and/or Amtrak representatives.

Dispatching functions are provided the BNSF Railroad from its Fort Worth operations control center, while crew qualification responsibility was apparently handed over to the Tacoma Railroad (TRMW), a shortline railroad, publicly owned by the city of Tacoma, which provides freight service over the line. It was reported that Tacoma Railroad kept no records of those it qualified, turning over all data to Sound Transit and/or Amtrak.

In all the discussions and documents available on WaDOT's and FRA's websites, there is exactly zero discussion of the mode of train operation. There is exactly zero discussion of the risks to safe train operations presented by the proposed track geometry and the proposed mode of operation. That doesn't mean there wasn't any discussion of those items, or that discussion did or did not include FRA. It just means there is no publicly available record of those discussions.

Perhaps there's some missing communication link or protocol between FRA's Office for Railroad Policy and Development, responsible for administering the grant and FRA's Office of Safety.

Perhaps not. In either case, FRA put itself in the position of approving for service an operating plan that included a track geometry and deceleration requirements that FRA had previously identified as presenting an unacceptable risk to safe passenger train operations.

Something else I learned from my railroad "teachers," as time went by: whenever you are asking a question about a problem or an incident or an accident on a railroad, you are really only asking one, and always the same question: Who's in charge?

Nature abhors a vacuum. Railroads usually fill one with wreckage.

David Schanoes

December 28, 2017

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dmschanoes@ten90solutions.com