Ten90 Solutions LLC

I received a comment regarding comments I made about PTC, spectrum availability, PTC 220, etc. in a previous post.

The comment pointed out that while the 220 spectrum was acquired by NS and UP prior to RSIA 2008, the designation of the 220 band as "the" PTC medium wasn't made an industry effort until after 2008.  

I agree.  However, the essential point is that Congress defined PTC by functionality  not technology.  The railroads opted for wireless data transmission, GPS, track databases, algorithmic based braking curves for satisfying these functional requirements. That decision took into account the already existing "ownership" of the 220 spectrum by UP and NS.

Now I'm not naive enough to think the lobbyists who wrote the legislation on behalf of Congress didn't have wireless data radios, GPS, track database, and algorithmic braking curves in mind,  rather than overlaying an enforcement  system based on existing track circuits, enhancing existing technologies of speed control, enhancing existing technologies for enforcing a positive stop, enhancing existing technologies for protecting work zones.  But again, that decision by the railroads as to achieving compliance was a commercial decision by the railroads, not a public safety decision. So I think it's a bit of a stretch to accuse Congress or FCC of dereliction of duty by not providing, free of charge, radio spectrum to the railroads.  Spectrum is, after all, a national resource.

If you ask me, and most of the time nobody is, I think commuter railroads should have "broken from the pack" with the Class 1s and not opted for the GPS, wireless data radio, WIU, GPS, BOS  type system.  

I think the commuter agencies should have made use of existing track circuits; should have made use of existing cab signaling technology; should have enhanced automatic speed control technology to meet the functionality requirements for PTC. 

I think the commuter railroads should have then developed their own methods for taking permission to enter a work zone out of the hands of the train dispatchers and putting it into the hands of the roadway worker in charge, the EIC.

I think the more I read about wireless data transmissions, the more I like track circuits  for determining occupancy.  Planes have been hacked, no?  Autos have been hacked, no?  Does anyone seriously think that we're not going to spend the next X years playing "cat and mouse" with those whose love for playing trains, and love for coding, compels them to try and change B23T11Z's authority for movement? 

The Class 1s opted for the wireless data radio/GPS/BOS/OBC system because approximately 40 percent of their trackage is dark territory-- without track circuits, without automatic block signals, without remote control and protection of mainline switches.  Automatic enforcement is impossible under these conditions because occupancy cannot and is not determined in the field. Class 1s require a system that can determine occupancy "virtually," and then practically enforce the conditions ahead of, and behind, that virtual occupancy.

That constraint, dark territory operation, is not the "default" operating environment for commuter service and should not have been allowed to determine the path taken by commuter providers in satisfying the functional requirements of PTC.  But.......

But it was, and it has.  The problems of interoperability with the freights if the commuter lines had opted for an "in-ground" system could have been resolved through "dedicated" locomotive fleets on the part of the Class 1s and the commuter lines-- a specific set of  locomotives equipped for operation over both systems, something railroads have been doing for years.

I think, and nobody's asking, that everybody has, or had, or has had, nothing but the best of intentions with regards to PTC.  (Except for the Schumenthal)   I think Congress had the best of intentions. I think the AAR had and has the best of intentions.  I think FRA had and has the best of intentions.  I think NTSB had and has the best of intentions.  And I think this is where we get when everybody has the best of intentions. 

So we have to accept where we are, and deal with it.  We have to push out the date. There is no point pretending we don't, or demanding fines, or "heads."   We have to require railroads to indeed layout how PTC will be installed in a)passenger service areas b)areas of high risk.  We have to provide FRA with the resources to oversee the implementation-- the supervision of this project. 

We do not have to blame the Congress for taking an action in the interests of public safety.  We do not have to pretend that business interests did not inform the practical decisions regarding implementation strategies and technologies. 

This is the world we live in.  No whimpering. 

August 13, 2015