Ten90 Solutions LLC

OK, so there's a couple of odd items, loose ends, I want to take care of. Everybody's talking about PTC and December 31, 2015.

Well, not everybody. But Schumer and Blumenthal, the unconjoined non-twins once and forever known as the Schumenthal are.

Near Miss Dick thinks the FRA should bring the mighty financial penalty hammer down on railroads not meeting the deadline, exempting of course the state of Connecticut which, according to Near Miss, has made a good faith effort in appropriating X amount of dollars.

That's mighty generous of Near Miss, except the state of Connecticut is not categorized as an owner or operator of rail service, and therefore is not subject to the requirements of 49 CFR 236. 

This should have been obvious to an expert like Near Miss, someone as intimately familiar with the regulatory process as he must be, because Connecticut has never filed a PTCIP, or a PTCDP, or a PTCSP, or an annual progress report with FRA, despite the fact that the state is the owner of certain locomotives and control cars which require outfitting with PTC enforcement equipment.

And as for "good faith" efforts, I think if you take the time to read the annual update reports filed in the PTC dockets it's obvious that the Class 1s have made efforts equal to if not greater than the efforts of many of the commuter railroads and commuter railroad agencies.  

Go ahead, read them and don't be afraid to tell me how wrong I am; how I misunderstand what's been happening in the industry; what a stooge I've become for the railroad barons.  Geez, if only Warren Buffet would notice..... 

Anyway, Near Miss Dick and Hold That Pose Chuck have flatly, repeatedly, explicitly opposed extending the PTC deadline....after the fatal overspeed derailment at Frankford Jct. in May of this year.  Before that?  Well, before that the Schumenthal was busy annuncing its sponsorship of Senate Bill 1006, the Positive Control Safety
Act which would allow FRA to suspend the mandatory December 2015 date for up to three years to 2018 as long as the railroad(s) met certain requirements. 

I was, and am, a bit confused by this. And who can blame me?  I mean one day in April, it's OK to push out the deadline, but one day in May, it's criminal. 

I thought I would contact the co-sponsors of Senate Bill 1006, Senators Blumenthal, Schumer, and Gillibrand, and ask him, her, it, them:  "Can you provide some clarification?  Do you still stand as a sponsor of Senate Bill 2006?  I'm just a poor boy whose intentions are good.  Oh lord please don't let me be misunderstood."  Thank you Eric Burdon, but we all know Nina Simone did the better version.  Actually, we all know that Nina Simone did the best version of any song she cared to do.  And Eric would agree.

But anyway, I contacted these senators via email through their websites, and by telephone in Ms. Gillibrand's case. Can you guess how many responses I received?  Zero?  You said zero?  Who told you?  No one?  Then the only explanation is that you are cynical and jaded beyond belief. 

So those are the odds and the ends. 

Here's something that worries me, the hard beginning. 

Metrolink, the railroad operation of the Southern California Regional Rail Authority commenced what is called "Revenue Service Demonstration" of its installed, and active, PTC system.  As part of the RSD program, SCRRA has filed weekly review reports, providing details on the total number of trains run on a particular line or sub-division, the total number of trains operating under the PTC enforcement system, the number of "missed opportunities"-- essentially trains operated without PTC active for any number of reasons including defects, crew not qualified, train not scheduled yet to run in PTC "mode" as the system is rolled out, etc.--, the number of PTC initiated braking events, and the number of enroute failures or exceptions requiring the cutting-out or disengaging of the PTC apparatus. 

Before we go any further, here's where I really do hope someone reads these reports and tells me how wrong I am; how I don't understand the data; how what I think is happening, the inability of the system to perform as intended, is not what is actually happening.  

I'm not a statistician, or a "technologist."  I have been a railroad operating officer responsible for safe train operations, and I know from that experience how vulnerable safe train operations become when the train control systems do not perform efficiently, consistently-- when such systems require repeated cutting out or deactivation. 

I have looked at eighteen (18) SCRRA's RSD reports.  Those 18 reports record 5,021 train starts; of those 5,021 trains, 1,314 operated in "PTC mode."  While operating in PTC mode, those trains experienced 206 events the required either cutting out or disengaging the PTC apparatus.  This is a cut-out rate of approximately 15.7 percent. 

I did all the math by hand so maybe I've got it wrong.  But if I don't I suspect we have a more serious problem than just the approaching December 31 deadline.  We have a system with unacceptably high failure rates, the requires deactiviation and will, in the near future, a) decrease safety in rail operations below current levels and, at the same, time b) effectively bring rail operations to a grinding halt. 

We would not, we did not, accept failure rates of this magnitude when installing and operating cab signal/automatic speed control systems.  We could not have accepted this failure rate and provided an efficient, safe service.

My take on the numbers in the RSD reports worries me even more when I look at the "missed opportunities" causes for trains that did not operate in PTC mode.  To be sure, most "missed opportunities" are due to the scheduling of rolling out the train into the program.  But my count for the number of  trains not operating in PTC mode for reasons other than "not scheduled" or "leased equipment; not PTC equipped;" because of an equipment failure, an initialization failure, a communication failure, crew failure, crew not qualified, inaccurate train information in database, delay in downloading bulletin orders, etc. comes to 446 trains.  Thus we have total failures, of some component in the PTC system, including the locomotive operator, of 206 (cut-out enroute) +446 (some form of initial failure) or 652 out of a total of 1314 + 446 train opportunities.  This is a failure rate of 37 percent.

Now I have been a big advocate of PTC, and for years.  And I've been that way for selfish reasons-- I know what it's like to dread the telephone ringing.  I know what it's like to drop your dish of ice cream when the phone does ring after 9 PM.   But I'd rather have those phone calls than what I see developing.   If my interpretation of these numbers is correct, and please, somebody show me how wrong I am, then the December 31 deadline is a non-issue.  The real issue is that we are compromising our rail service.  

September 22, 2015

"Maybe we can build a fire, sing a couple of songs, huh, how about we try that."-- Burke, Aliens