Ten90 Solutions LLC

I had the pleasure, October 20 and 21, of attending.......wait a minute lets start again. I had the pleasure, October 20 and 21, of clicking into the Railway Age/Parsons Next-Gen Train Control Webinar.  

I enjoyed the Next-Gen conferences, when they were conferences.  Most of the time.  The one exception was the October 2018 conference held at Le Meridien Hotel in Philadelphia, Pa. Somebody had turned the thermostat in the conference room to its "Polar Ice Cap- Planet Mars" setting.   I spent several hours attempting to build a fire under my own seat. If I could have stopped trembling long enough to speak I would have claimed building a fire was an act of free speech, but in space no one can hear you shiver. 

Anyway, this webinar wasn't like that.  I was home, it was 70 degrees outside and about the same inside; the laptop was throwing off additional heat; my Beats by Dre headphone/ear muff combination was working as intended. I was wearing a sweater and a scarf.  I was ready to tune-in, click on, and virtually  participate like the thoroughly modern person my family knows me not to be.

Have I ever mentioned how much I hate being cold?  No? Well, let me say just a few words about that:  Chicago,  February, twenty eight Februarys.

If you can access the archive of the webinar, and I don't know that it's available to the non-registered people, I particularly recommend the presentations by Alex Barron of Britain's Transport Strategy Centre "Very High Frequency Success Factors: Experience from the Global Community of Metros," and the presentation by Eileen Reilly, CEO, Global Train Services LLC, "Next-Gen: PTC 2.0."   

Back on Mars, at the 2018 conference I was on a panel, the topic of which I forget, probably because of the pain associated with the memory. Battling hypothermia, and noticing between tremors that I was seated next to Carolyn Hayward-Williams, Director-Office of Railroad Systems and Technology, Office of Safety, FRA. I thought I would try to generate some heat by asking a question of my own panel along the lines of:

"We've heard a lot about the technology, components, networks that go into making a viable PTC system, but I'd like to know how reliable these system are? What about their performance? Is anyone keeping track of that?"

I thought it was a good question. I thought that it had to be good since that might be the last question I ever asked before succumbing to the cold, and freezing solid.  That way, my epitaph would be a snap:  "He asked good questions.  Pity he couldn't stand the cold." 

Again, I don't recall the exact answer and again I blame the cold, but to the best of my recollection I believe Ms. Hayward-Williams answered something to the effect of: "FRA is monitoring this. Don't worry."  (Note: Again, I don't guarantee the dialogue is verbatim, but I think that was the gist). 

Now if I hadn't been so sick with cold, that--being told not to worry--would have made me worry.  Generally, people who tell me not to worry think they know more than me. The people who actually do know more than me do a lot of worrying themselves and have never told me not to worry.  Ever.  Such individuals who know more than me have told me to shut-up; to get out of the office; to pound sand; to hold my breath and turn blue etc. etc. One of those people actually tried to strangle me with my own necktie.  On two separate occasions! I fixed him. I went to business casual attire everyday.

Well, there's good news.  Ms Hayward-Williams made another presentation on behalf of FRA at the webinar, and this presentation includes information about PTC failures. 

And the there's the bad news:  I can't make sense out of it.  Sounds like a personal problem, you say in your best railroad voice?  OK, let's find out.   

As part of the legislation enacted by Congress extending the "install by.." date for PTC to December 31, 2020, 49USC 20157 requires that:

During the period described in paragraph (1), if a positive train control system that has been certified and implementedd fails to initialize cuts out, or malfunctions, the affected railroad carrier or other entity shall submit a notification to the appropriate regional office of the Federal Railroad Administration within 7 days of the system failure, or under alternative location and deadline requirements set by the Secretary, and include in the notification a description of the safety measures the affected railroad carrier or other entity has in place.

FRA then initated the appropriate procedure seeking comment on its proposed regulation implementing this requirement and after considering the received input came up with FRA Form F 6180.177, available here as part of FRA's PTC Collaboration Session held in June 2020. 

FRA requires that a host railroad with a fully implemented, fully interoperable, FRA-certified PTC system, must submit the completed form detailing failures to initialize, cut-outs, and malfunctions of PTC by the 15th of each month following the month the report itself covers.  Host railroads must submit the same information for tenant railroads operating through their PTC territory.

Got that? Bueno, alors, cosi.  We'll move on. 

The reporting railroad must report the total number of scheduled PTC-required train miles.

The report does not require documenting the number of PTC train-miles actually completed. 

The report does not require submitting the programmed number of trains scheduled to operate through PTC territory. 

The report does not require submitting the number of trains that complete their schedule with PTC engaged.   

Bueno, alors, cosi.  In her presentation, Ms. Hayward-Williams provided the following information for the following time periods: 

Reporting Periods:   6/30     7/31     8/31

#Fail to Initialize:   3466       486     345 

#RRs                          10          6          7

#Cutouts                  9759       1797   1759   

#Malfunctions         22,430    2200    2190

#PTC Trn Miles      75,675     9501   9579

(PTC train miles are in thousands; 75,675 equals 75.675 million train miles)

So beginning at the beginning: 

1) FRA reports 15 railroads have certified safety plans and operable PTC systems, accounting for coverage of 99 percent of the mandated track. Why are only 10 railroads reporting for June; 6 railroads reporting July; and 7 for August.  Is the supposed to mean 5 railroads experienced no failures in June; 9 had no failures in July; 8 had no failures  in August? 

2) In the presentation Hayward-Williams calculates the rate of initialization failures to PTC train miles; the rate of cut-outs to PTC train miles; the rate of malfunctions to PTC train miles, all things that make me go "hmm.." Or...exactly what are we comparing? 

Calculating the frequency of initialization failures to schedule PTC train miles is not a viable metric.  Initializations are train related, not mileage related.  The rate to be calculated is failures to attempts; failures to total initializations.  Failure to trains operated, if the trains are allowed to operate after the failure.

Now the rate of cut-outs and malfunctions can be related to the scheduled PTC train-miles, but the better metric is the rate per PTC-equipped train movement. 

I have little to no idea what the rates presented by Hayward-Williams really indicate, and I suspect I'm not alone.   

If anyone knows how many trains are operating through PTC territory, with PTC compliant locomotives per day, week, month or fiscal quarter and has an idea as to how many of those trains experience an initialization failure, a malfunction enroute, and/or a cut-out of the PTC system, don't hesitate.  Get in touch with me quick.  It's already the end of October, and I'm  feeling the urge to hibernate. 

David Schanoes

October 22, 2020

"The simple things you see are all complicated, 

I look pretty young, but I'm just back-dated"

--  The Who, "Substitute"