Subject: Response to PTC commentary at two Transportation Research Board sessions
From: "Ross Capon" <[email-masked]>
To: "Ross Capon" <[email-masked]>
Date: Tue, 31 Jan 2012 07:26:56 -0500

To our friends at Amtrak:

In the following commentary, Item 6B will be of particular interest to passenger train advocates. Our focus is on getting PTC done right. It is important that any law extending the deadline also clarify what needs to be done.

--Ross B. Capon, President & CEO
National Association of Railroad Passengers
505 Capitol Court NE, Suite 300
Washington, DC 20002-7706
202-408-8362 (mobile 301-385-6438)
www.narprail.org<http://www.narprail.org>

The items below respond to some comments about PTC at TRB session 324 on January 23 Freight Rail Innovation: Opportunities and Challenges (e-Session)<http://pressamp.trb.org/conferenceinteractiveprogram/EventDetails.aspx?ID=23110&Email=[email-masked]> or session 610 on January 24 Positive Train Control: Implementation Challenges and Possible Solutions<http://pressamp.trb.org/conferenceinteractiveprogram/EventDetails.aspx?ID=23713&Email=[email-masked]>. The presenters at these sessions were:
#324 Freight Rail Innovation: Opportunities and Challenges (e-Session)<http://pressamp.trb.org/conferenceinteractiveprogram/EventDetails.aspx?ID=23110&Email=[email-masked]>
  FRA Perspective (P12-5790)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=51437&Email=[email-masked]>
     Szabo, Joseph C. - Federal Railroad Administrator
  AAR Perspective (P12-5791)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=51438&Email=[email-masked]>
     Hamberger, Edward R. - Association of American Railroads President & CEO
  Industry Perspective (P12-5792)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=51439&Email=[email-masked]>
     Young, Jim - Union Pacific Railroad and Union Pacific Corporation Chairman, CEO and President
  Legislative Perspective (P12-5793)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=51440&Email=[email-masked]>
     Shuster, Bill - U.S. House of Representatives (regrets)
#610  Positive Train Control Risk Assessment Using Rare-Event Simulation (12-3810)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=49526&Email=[email-masked]>
     Meyers, Timothy - DecisionTek, LLC
     Brod, Daniel - DecisionTek, LLC
  Positive Train Control Roadblocks and Potential Resolution (P12-6370)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=52018&Email=[email-masked]>
    George Hartman, Specialist, Signal and Train Control Division, Federal Railroad Administration (substituting for McFarlin, Tom, Staff Director, Signal and Train Control Division)
  The Economic Impact of Positive Train Control (P12-6845)<http://pressamp.trb.org/conferenceinteractiveprogram/PresentationDetails.aspx?ID=52548&Email=[email-masked]>
     Carl VanDyke, substituting for Rod Case - Oliver Wyman Inc.  (formerly Mercer)

1. The future of GPS is not shaky. References to doubt about the future reliability of GPS revolve around LightSquared which purchased a lot of spectrum intended for satellite uplinks. LightSquared wanted to divert this to ground applications, which indeed would have caused problems with GPS. However, because GPS is so vital to the Pentagon, aviation and many other industrial and consumer applications, the FCC will not approve changes that threaten GPS. At a December 21 Pentagon briefing, Lt. Gen. Larry D. James, Deputy Chief of Staff for Intelligence, Surveillance and Reconnaissance, HQ U.S. Air Force, was asked about LightSquared. He responded that the USAF and the FAA have the matter well in hand, and that LightSquared will be shifting its frequencies away from those used by GPS. This should not be surprising, given how vital GPS is to both the military and aviation. The Next Generation Air Traffic Control system is being based on GPS.

2. The European rail experience was cited as a mark against PTC and GPS. The European version of PTC (European Rail Traffic Management System - ERTMS) uses track-based transponders (ballises), like ACSES. However, this is because the European Union did not want to rely on GPS, a system managed by the US military. When Galileo (European version of GPS) becomes operational, ERTMS will use it.

3. Sharp variances in the braking distances required for different trains is cited as an obstacle to PTC, or evidence that PTC will reduce track capacity by requiring a “lowest-common-denominator” approach to braking, which one individual suggested would cause some trains to “come up a mile short,” that is, to brake far earlier than necessary. The braking algorithm issue simply points out why train consist information (length and weight) which already exists in railroad computers and on paper consists handed to train crews needs to be loaded into PTC on-board computers so that they know when to apply the brakes at the right time to bring the train safely to a stop at the end of its movement authority.
4. FRA regulations do not require the PTC “system [to] be designed to determine the position of the end of the train.” See text atop page iii (computer page 4) at http://www.fra.dot.gov/downloads/PTC_%20RIA_%20Final.pdf Two rear-end collisions and four engine-crew fatalities in April and May of 2011 would not have been prevented by PTC as we understand the system is currently envisioned.

5. It is said that many of the benefits sometimes attributed to PTC are already being realized by the railroads independent of PTC. To the extent that this is true, it reflects a decision by the industry to ignore and fail to build on the ARES experience 30 years ago. This is  the functional PTC system that Burlington Northern ran on the Minnesota Iron Range, covered more distance (250 route miles), more different types of territory (dark, ABS, CTC), for more time (5 years) than any PTC tests on any other railroad up to today. 2. The European rail experience was cited as a mark against PTC and GPS. The European version of PTC (European Rail Traffic Management System - ERTMS) uses track-based transponders (ballises), like ACSES. Draper Lab conducted a rigorous reliability analysis of ARES, showing how a PTC system can reduce the probability of collisions and overspeed accidents by a factor of 100.

No one forced the railroads to leave PTC work to the end so they could lambast it as an unfunded mandate. Moreover, it is doubtful that the railroads are actually getting all of these related benefits claimed. NS was cited as a ‘single- railroad’ doing fine with its new train dispatching system. According to the Oliver Wyman study, NS only gets locomotive location signals every 15 minutes, which is incompatible with the efficient operation of a high-density railroad such as Chicago-Cleveland (although one presenter referred to NS as a ‘single-track railroad’).

6. By insisting on an overlay system, that is, indefinite retention of wayside signals even after PTC is proven, the railroads are driving up the costs and reducing the benefits of PTC. The main reason cited for overlay is the tight deadline. Therefore, NARP would support an extension of the deadline if the new law makes clear what PTC is to do. The railroads spend about $9 billion a year on legacy, wayside signals which ought to be headed for oblivion. Instead, most railroads are upgrading these signals at considerable cost.

6A. Retention of wayside signals means retention of fixed blocks, as well as block occupancy and relay logic, and thus lower capacity than what would be possible with moving blocks and continuous, real-time information regarding train location and speed.

6B. If legacy signals are phased out (which FRA has told us would be possible on the basis of specific applications), the proportion of signal system costs which are wayside falls significantly. It then becomes feasible to cover the entire network with PTC, which produces far more benefits than a “pick-and-choose” system would. The fact that full network coverage lowers the incremental cost of adding passenger (or TIH) service does not detract from the reality of the economic benefits of universal coverage to the freight operation—benefits which at least one railroad official freely acknowledged before the 2008 law was enacted.

7. Radio specifications are not complete yet. This is true. The railroads got off to a late start working on the spec, and never hired a systems integrator. The railroads are attempting to handle integration internally but it is not clear that they have this capability. Proven system integrators include, in alphabetical order, Boeing, Draper Lab, IBM, MITRE, Parsons and SAIC. The specs for digital data radios are a separate problem. This is being tackled by Meteorcomm, a company jointly owned by the four biggest railroads and which has not previously undertaken a project of this magnitude. Other, more experienced radio manufacturers have complained that they have been totally cut out of the radio design activity.