“We”—old timers, old heads, just plain old—sometimes refer to ourselves as “fossils,” but we’re not really. Fossils, as far as “we” know, can’t think, change positions, make jokes, whine, or delude themselves and others. We can, like human beings, do all of that and even do all of that at once. I could give you an example (of dubious value, of course), but not today. Today belongs to my fossildom.
Anyway, FRA has published its Notice Of Proposed Rule Making (NPRM) amending certain regulations governing PTC systems (Docket No. FRA-2023-0064). Two of the amended rules are intended to address circumstances when PTC failure currently prevents the dispatch of an individual train, or in the case of “system failure,” multiple trains due to an inability to initialize the PTC system prior to departure from the initial terminal. The third proposal specifies and enhances both the information that railroads must provide FRA and the safeguards the railroads will institute when a railroad requests FRA permission to temporarily disable its PTC system when necessary to perform maintenance, repair and upgrades, as provided under 49 CFR 236.1021 (m).
First things being first, just what is initialization? FRA, for its part defines “initialization failure” instead, which is totally appropriate given the different systems in use to satisfy PTC functionality. That definition:
“[A]ny instance when a PTC system fails to activate on a locomotive or train, unless the PTC system successfully activates during a subsequent attempt in the same location or before entering PTC-governed territory. For the types of PTC systems that do not initialize by design, a failed departure test is considered an initialization failure for purposes of the reporting requirement under § 236.1029(h), unless the PTC system successfully passes the departure test during a subsequent attempt in the same location or before entering PTC-governed territory.”
Short version: failure to activate. FRA states the intention of the proposed rule is “to establish an exception, under 49CFR 236.1006 (b)(6), to permit, under certain conditions, non-revenue passenger equipment to operate to maintenance facilities or yards, without being governed by PTC technology.”
Simple enough, initialization failure? OK to operate the equipment deadhead from its terminal to the place of repair with PTC inoperative, provided the railroad does C, D, E, F?
Swell. What about A and B, before we provide a blanket authorization? A: How big a problem is this for commuter railroads, which is another way of asking how many initialization failures did these railroads endure? Well, believe it or not, FRA actually provides data on these failures:
“For example, railroads’ Quarterly Reports of PTC System Performance show that PTC technology failed to initialize on approximately 236 intercity passenger or commuter trains and 894 freight trains in 2023.”
OK: 236 in a year? There are, in the US, 24 entities providing passenger or commuter service subject to PTC requirements. Amtrak runs more than 300 trains daily; Long Island Rail Road runs about 950 daily. Last time I checked, Metro-North was running about 750, passengers and deadhead equipment, in and out of Grand Central Terminal daily. That’s about 2,000 trains daily. If all 236 initialization failures occurred on just those railroads, putting aside daily trains operated by NJT, Metra, Metrolink, MARC, MBTA, NICD, Caltrain, RTDC, SMART, Sound Transit, Tri-Met, VRE, UTA, SEPTA, SFRTA, TRE, etc., the rate of failure amounts to 0.00032329, less than 1 in every 3,000 trains.
Well, hats off to the reliability of the PTC systems governing the nation’s passenger service, but that reliability means there is no case to be made for relief from the current regulation.
That’s A. B? Just this: PTC is not the first or the only regulation prohibiting movement from an initial terminal with defective or inoperative train control apparatus. Back in the pre-PTC days, railroads operating trains at speeds equal to or greater than 80 mph were required to install cab signal equipment that would convey, via illuminated signal inside the operating cab, the maximum speed permitted based on the conditions in advance of the train. The cab signal system must be supplemented by a train stop or a train control system that automatically applies the brakes and reduces the train velocity to zero (0) should the locomotive engineer fail to take a required action within a required time.
Now, I think Metro-North Railroad completed installing the roadside equipment necessary for cab signal/train control operation in 1991. The on-board equipment installed on every locomotive, control car and EMU was very reliable, and like all very reliable equipment, it sometimes failed. I calculated that the railroad experienced one (1) cab signal/train control every 1,100 train movements.
49 CFR 236.566 requires that “the locomotive from which brakes are controlled, of each train operating in automatic train stop, train control, or cab signal territory shall be equipped with apparatus responsive to the roadway equipment installed on all or any part of the route traversed, and such apparatus shall be in operative condition.”
Not OK to run it without passengers; not PK to run with a speed restriction or a head end block; not OK to run it with an extra crew member on the head end. Just, “you can’t do it; don’t try it.”
And never was I prevented from moving a train with failed train control equipment to the shop for repair because I couldn’t “cover” the failed locomotive with another locomotive properly equipped with operating train control. We didn’t need “relief” from that regulation then. There is no need to provide relief from the requirement for operable PTC now.
More to come …
David Schanoes is Principal of Ten90 Solutions LLC, a consulting firm he established upon retiring from MTA Metro-North Railroad in 2008. David began his railroad career in 1972 with the Chicago & North Western, as a brakeman in Chicago. He came to New York in 1977, working for Conrail’s New Jersey Division. David joined Metro-North in 1985. He has spent his entire career in operations, working his way up from brakeman to conductor, block operator, dispatcher, supervisor of train operations, trainmaster, superintendent, and deputy chief of field operations. “Better railroading is 10% planning plus 90% execution,” he says. “It’s simple math. Yet, we also know, or should know, that technology is no substitute for supervision, and supervision that doesn’t utilize technology isn’t going to do the job. That’s not so simple.”
