Ten90 Solutions LLC

Dear Bill,

As you know I've written about PSR before on neither side except the singularly unimpressed side. I've said that PSR is nothing new. It's value is supposed to reside in that holy grail of all transportation enterprises, optimum asset utilization. Maybe it does, but if it does it's nothing new; it's what every railroad tries to do, has to do, to stay in business. Big deal, or rather, "what's the big deal?"

Hunter Harrison's compensation from CSX, now that was a big deal, I understand, but that certainly can't be the motivating force behind the executive enthusiasm for PSR. Can't be. Sure this is the land of opportunity, but let's get a grip.

Besides, what I was told when I was a young and a bit wild trainmaster ("headcase" they called me) by higher ranking officers both sympathetic and non-sympathetic to my unique way of doing things, "Nobody's irreplaceable," applies today and from bottom to top.

A railroad paying $700 million to anyone has some determining interest other than providing the safest, most efficient service it can. But that's not the subject of debate.

Our learned senior fellow and chair in Operations and analytics claim that railroads better starting guarding their wallets because Rep DeFazio is coming for them. Well, actually he's not. He's asking questions. He wants to study the impacts, the effects that PSR has on the operating environment. Now that's not a threat. That's... business. You can't manage what you can't measure, and so far, nobody has produced the metrics that can measure the changes to operating efficiency and train safety precipitated by the adoption and adaptation of PSR.

Now that might be because nobody knows what PSR is, or to put it another way, PSR is anything the executives at a particular railroad say it is. "Scheduled service"? Sure thing, PSR. How does this differ from what railroads have established in passenger service, and have attempted to establish in freight? Beats me.

"Longer trains"? Well, here's the thing, longer trains are harder to operate to a schedule, It's a fact. Remember "BT-LT-OT"? Big trains, Less trains on time.

"Shorter trains"? That's PSR, too. The schedule says the train leaves at 7 PM, not 7 + X hours PM.

Besides the length and weight of trains have nothing to do with PSR. Trains were getting longer and heavier for years before PSR, and if that length and weight have increased dramatically in the last decade, it's due to technology, the technology of radio controlled distributed power, which has taken advantage of improvements in the design of freight cars to carry heavier weights in longer trains.

Messrs Brannon and Gorman doubt the validity of concerns that PSR will lead "to more train accidents as well as unhappy customers and overworked employees, potentially jeopardizing the long-run health of the railroad industry."

They tell us "However none of the objections stand up to the least bit of scrutiny," without providing, on their part, the least bit of scrutiny.

That's a swell way to prove a point: claim any dissenting view can't stand up to scrutiny, and then move on.

Those of us who have been doing this for awhile, evaluating operating programs for safety and efficiency are kind of partial to scrutiny, We call it data-driven, or "objective analysis," or aggregate product of years of experience, but scrutiny is the foundation of making an informed practical, rather than ideological government.

So let's apply a little scrutiny to some of these concerns. We all know about the customer complaints that have been triggerred by the roll-out of so-called "PSR," so we can take debate points away from Messrs Brannon and Gorman for that.

But let's look at train accidents. Now, full disclosure: I have no idea if any single one of the train accidents I've reviewed were caused by so-called PSR, but I'm not interested in any single accident. I just want to know if anything has changed pre and post adoption of PSR, in the frequency of train accidents that might cause concern in an operating officer, and push her or him to look at more cases with a bit more scrutiny.

So just for fun, let's say we take the 8 years 2013 inclusive to 2020. For more fun we will divide them into a pre PSR period 2013-2016, and a post PSR period of 2017-2020. And for more fun we'll compare them for the frequency of train accidents not including grade crossing accidents.

For fun we'll find the frequencies, the rates of:

train accidents per total train miles;

train accidents per employee hours;

on duty injuries per employee hours;

employee fatalities per total train miles;

employee fatalities per employee hours.

(Note: the raw data is taken from FRA safety data tables; the calculations are mine. As much as I might like to hold FRA responsible for any errors, I can't. They're mine).

So frequency of train accidents:

2013-2016-- 1 (one) every 398,192 train miles; 2017-2020-- 1 (one) every 364, 107 train miles.

2013-2016-- 1(one) every 251,815 employee hrs 2017-2020-- 1(one) every 226,682 employee hrs

In both cases train accidents occur with greater frequency in the 2017-2020 period.

So on duty injuries per employee hours:

2013-2016-- 1 (one) every 112,814 hours; 2017-2020-- 1 (one) every 116,388 hours.

An improvement of approximately 3 percent.

So on-duty employee fatalities:

2013-2016-- 1 (one) per 61.6 million train miles; 2017-2020-- 1 (one) per 58.1 million train miles. 2

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dmschanoes@ten90solutions.com