Ten90 Solutions LLC

The final rule also allows for "yard transfers" of cars hauled by non-PTC equipped locomotives within PTC territory for distances up to 20 miles.  Again FRA accepts a speed restriction on the movement as a substitute for the positive enforcement of PTC. 

The wireless data platform upon which PTC is erected changes the train control system from a process containing two distinct elements into a system where the boundaries between the  two elements become obscured.  The two elements are 1) the detection of occupancy-- the vital process determining movement authorities, and 2) the communication of that condition to following or opposing trains. 

In the wireless data platform, occupancy is determined only through the communication process.  The locomotive becomes the node of communication. Its location, determined by the locomotive's on-board systems utilizing  GPS  no longer exists separate and apart from the locomotive's communication of that location. That's what "virtual" means.  The train transmits its occupancy to the train control system. 

This provides great opportunities for economies and improvements; and opens new areas of risk. This "comingling" of elements means PTC becomes more than just an overlay system.

For example, it is likely that the application of PTC in "dark territory" will provide a platform for all trains so equipped to communicate with grade crossings through the application of the WIUs to the crossing mechanism.  Without going to the expense and labor of installing approach circuits, island circuits, and the necessary release mechanisms; by simply extending the wireless data platform already in use for PTC, railroads could save hours of delay, significant money, and perhaps a few lives, by installing gates activated by a train's data radio communication. 

What happens when the unequipped train now operates over this territory?  What activates the gates then?  Nothing.  When the crossing protection is known to be inoperative, what must the train do?  Stop and flag every crossing.  Does that sound like progress to you?

Finally, FRA delivers this:

236.1029 PTC system use and failures:

(g) Temporary exceptions. From October 21, 2014 through the 24 months following the date of required PTC system implementation established by section 20157 of title 49 of the United States Code- 

(2) a train may proceed as prescribed under either paragraph (b) of this section or 236.567 where the PTC system fails to initialize for any reason prior to the train's departure from its initial terminal. 

Get that?  A train may depart its initial terminal with a failed or defective on-board computer.  The train's maximum permissible speed will be determined by the type of signal system, if any, in use, and the type of service provided.

Passenger trains can operate at 59 mph; freight trains 49 mph; trains with PIH in consist, 40 mph except where cab signals and automatic train control is in use, and then trains may operate at 79 mph. 

That's quite an exemption offered by FRA.  I mean if you check 229.117, you'll see that it's a violation to dispatch a locomotive from its origin with a defective speed indicator.  If you check 236 Subpart E, you'll see that it is a violation to dispatch a train from its origin with any one of a number of defects in its cab signal and/or automatic train control systems.... so exactly why is FRA allowing locomotives with defective on-board PTC computers, where initialization (the downloading of the limits and restrictions to movement authorities; the locations of work zones; temporary speed restrictions etc) has failed, to depart its initial location? 

Establishing direct, transparent procedures and regulations for PTC installation and operation  is a huge challenge.  FRA has not met that challenge.

Else there won't be no harps and angels coming for you
It'll be trombones, kettle drums, pitchforks,and tambourines.

Randy Newman, "Harps and Angels