Ten90 Solutions LLC

Fun Fact:  Train movements in Penn Station, New York, are managed using a computer with enough processing power to handle the 900,000,000 shares traded daily on the New York Stock Exchange.

Impressive, right? Not really.  All that means is that every train movement, every aspect of controlling train movements, can be expressed in simple terms of exchange, like buy and sell, or plus and minus, or on and off, or one and zero, or if, then.  In the business of train movements, the plus and the minus, the one and the zero,  are expressed as "go"  or "no-go."  It's simple.  The calculations are simple.  Easy as p-i-e. 

You could do it with a pencil and paper, and I do mean you.  Or me. And I do mean pencil and paper.  

The problem is doing it quickly, efficiently, reliably enough for multiple trains moving through multiple "go, no-go" points.  The problem comes with density, frequency, opportunity. That's when and where electrons beat the hand and the eye. But the math itself, the "go, no-go," the one or zero, that's not that hard.  

My finely tuned expertise in simple math has allowed me to determine that over 20,000 route miles of the US railroad system are now equipped for PTC operation and are either in the revenue service demonstration phase (RSD), or have graduated from the RSD course and are in full PTC operation. 

Simple, that is to say pencil-and-paper, math tells me that 20,000+ miles is about one third of the total mileage requiring PTC coverage. 

Pencil-and-paper math also tells me that approximately 3000 trains a day are operating over territory where PTC systems and rules are in effect.  Most of that number is concentrated in and connecting to Amtrak's Northeast Corridor where ACSES II is the PTC platform, but at least ten percent of the total is systems utilizing GPS, wireless data radio based like Wabtec's I-ETMS and GE's ITCS. 

That should give us lots of information, "data points" for you ultra-moderns, to make some determinations about how well these systems are functioning. 

So, how are we doing?

Prior to approving a railroad's application to begin revenue service demonstration, FRA requires that the railroad validate the I-ETMS track database for the segment of track utilized in the demonstration.  This means railroads must verify that the information in the database pertaining to mileposts, signals, stations, switches, grade crossings, permanent speed restrictions, block limits, etc. actually corresponds to everything that exists in the field. 

Sounds difficult?  It sounds difficult, but it isn't.  That's exactly what we do when we write a timetable-- we have to make sure that everything we annotate in the timetable, and the timetable special instructions, corresponds to what's in the field.

We think it's difficult when transposing this information to a database because the format, the language, is different.  Then we have to rely on specialists to translate one format into the other, and translate it into a format that is intelligible to machinery absent, or even in opposition, to the actions of the human operator.  That part's different. 

During RSD, FRA requires that the railroad operate a minimum number of trains without encountering a "critical anomaly."  That minimum number is one hundred.  FRA requires:

During this phase any critical anomalies that may affect the safety of train operations shall be reported immediately to the test monitor or to the designated representative.  The following failures of an I-ETMS system are categorized as critical anomalies:

a)failure to enforce brakes....

b)overrun of authorithy boundaries...

c)unintended enforcement.  This is an erroneous generation of brake application command without warning or when it was not required

FRA requires a monthly report.   The monthly summary report must include:

1) the monthly total of all train starts in the territory and the number of starts with I-ETMS locomotives in the lead

2)the number of train starts for which the I-ETMS was operative on-board the locomotive

3)an itemized listing of I-ETMS initiated penalty brake applications, including circumstance and a determination of the penalty, intended, predictive, or reactive

4) a listing of each system anomaly or system failure and...corrective actions...;the total number of operating hours in which the system was functioning; the total number of hours before failure;...the total elapse time(s) between repeat failures 

5)determination of root cause of each failure...

6)any failure of I-ETMS to initiate enforcement when enforcement was appropriate

7)any instance where equipped locomotives assigned to the RSD failed to initiatlize

8)any instance where an equipped locomotive operating in RSD transitioned from "engaged" to the "disengaged" status

9) any instance where an equipped locomotive operating in the RSD had to have the on-board PTC apparatus cut-out

10) any other I-ETMS system anomalies that may have a bearing on safety or system reliability. 

Well, we have our miles and miles of tracks in RSD or in full PTC operation.  We have our definitions of critical anomalies.  We have 10 mandatory reporting points.  We have our pencils and papers.  So we should have data pouring out of ears, metaphorically speaking, but more importantly, we should have all the data we need at our fingertips to tell us how well we are doing.  So......  So how well are we doing? 

The truth is we don't know, if by "we" we mean you and me, us, the public.  I know that's what I mean when I say "we."

"We" can go to the government website www.regulations.gov and "we" can enter the docket numbers for the individual railroads required to submit information to FRA regarding PTC, and "we" can look at the information submitted by BNSF, NS, UP, CSX and almost all the other railroads with sections in RSD or full PTC operation and we'll come up with......nothing.

Where reports are even included in the dockets, the reports are completely, totally redacted.  I mean more redacted than the Congressional investigations into Iran-Contra or 9/11 are redacted.  To my knowledge, only the Southern California Regional Rail Authority, Metrolink,  has allowed public access to its summary reports regarding PTC revenue service demonstrations on its territories. (And if I have missed or ignored  railroads that have also allowed public access to those reports, please contact me, so I can issue apologies both public and private). 

FRA says that if a railroad designates the information submitted in the required monthly reports as "proprietary," the railroad can redact the information from public review.  FRA says that in fact a railroad can declare the very format of the report as "proprietary" and then nothing will appear in the public docket. 

I don't get that.  I don't see how the results of  installing a train control system mandated by law as a matter of public safety; with regulations directing the requirements for implementation and validation of the installation and operation of the legally required train control system can be subsumed under the umbrella of "proprietary information."  I'm no lawyer, I'm happy to say, but..what? 

But this:  Nothing prevents FRA from "scrubbing" the information it receives in the monthly reports from the various railroads of all identifying characteristics-- eliminating names, locomotive numbers, mileposts, stations designations and other identifying characteristics and then presenting a summary of the data received in terms of event, frequency of occurrence, mitigations proposed-- you know all those things that are so easily calculated and reported with pencil and paper. 

Hell's bells, boys and girls,  FRA is all for doing that when it comes to close-call confidential reporting.  So why doesn't FRA provide us with:

1) a monthly summary, without identifying any particular property,  of the total number of train starts in PTC RSD, and PTC territory with I-ETMS equipped locomotives in the lead? 

2) a monthly summary of the number of train starts with I-ETMS operative on-board the lead locomotives? 

3) a monthly summary of the number of  I-ETMS initiated penalty brake applications, and a distribution of such penalties: intended, predictive or reactive? 

4) the total number and type of system failures and critical anomalies; the aggregate  of PTC, or PTC RSD service hours; the average hours until first failure; the average service hours between failures? 

5) the number of failures per "reason for failure"? 

6) the number of failures to enforce when enforcement was appropriate? 

7) the number of instances, and percentage of total instances, when the locomotive failed to initialize? 

8) the number of instances when locomotives transitioned from engaged to disengaged; the average time, and distance traveled,  for the return of the locomotive on-board system from "disengaged" to "engaged" status? 

9) the number of instances when the locomotive on-board system were cut out when operating in PTC, PTC RSD territory? 

10) any other anomalies that may have bearing on safe-train operations? 

I remember-- and if I remember you know it can't be that long ago because I can barely remember the plot of the movie I saw last night-- that there was this report commissioned by AAR.  The report attempted to gauge the possible failure rates of the various components making up the PTC system, and the impact those possible cumulative failures would have on network velocity.  I think I remember the report concluding that overall reliability of the PTC system would be below 99 percent; above 98 percent, but below 99 percent, and that the impact on network velocity would be......if not catastrophic than dramatic, or at least substantial.  Anybody else out there remember that report? 

So wouldn't it be nice to know if that report has been substantiated or refuted by actual PTC RSD and PTC operation?  

Why, in short, doesn't FRA feel itself obligated to report to the public the information, scrubbed of all proprietary characteristic, that it requires the railroads to report?  Too much work?  Too complicated?  Come on,  this is simple math. 

This is pencil and paper stuff.  I could do it in my sleep. 

I think FRA doesn't do it because FRA doesn't think it's obligated to do it.  And I think we all have the pencils and the papers to correct FRA's misperception. 

David Schanoes

October 22, 2017

Great moments in rock and roll history:  1965, The Who release "Can't Explain."