Sunday, September 14, 2014

So, you want to know my opinion?

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So, you want to know my opinion?
Somebody asked me my opinion, and you know how dangerous that can be...

After the Federal Railroad Administration announced its proposed rule-making on mandatory train crew size; after BNSF and SMART announced a tentative agreement on single-person operating crews for certain trains on certain routes; after the rank and file of SMART emphatically rejected the tentative agreement, arguing that single-person crews represent a risk to safe train operations, somebody asked me if I thought that the threat to safety was the biggest obstacle to single-person crews.

I don’t. I believe there are arguments to be made for single-person crews, and arguments to be made against single-person crews, but I don’t think safety is one of those arguments, on either side of the question.

First and foremost, there is no data indicating that single-person crews are any less safe than multiple-person crews when it comes to actual train movements. Passenger and commuter rail service has operated for decades with a single person in the operating cab with greater operating safety than multiple people in the cab in freight service.

Of course, the two services differ. Passenger runs are scheduled, train consists are fixed, more or less, and in-train forces are much lower than those forces in freight trains. Passenger runs also have additional crew members to handle unusual circumstances—like making a reverse move, flagging a crossing, or setting out a defective car. But those are the demands of the service, not safe train operation.

Way back in the day, when advanced train control systems with positive stop and overspeed prevention capabilities were being proposed, designed, and debated, there was considerable concern that the safety capsule was a poison pill for crew consist agreements. I certainly don’t think that concern alone was enough to deter the railroads from pursuing and installing PTC. It was the cost of installation, expressed as the cost-benefit differential, that was the obstacle.

However, BNSF, being forward-looking, proposed a reduction in crew consist size based on the additional safety PTC will provide to the operating environment. Certain trains operating in PTC territory were to be eligible for single-person operation.

Sure enough, if human error is the single-largest cause of reportable main line train accidents, and if PTC is capable of eliminating 99.99% of those human error causes, then BNSF and the other railroads might have an argument based on improved safety of the operation.

The thing is, the way FRA has executed the law in its regulatory requirements, the interpretations FRA has attached to the requirements of the law, and the exemptions given for non-PTC equipped train operation in PTC territory, the probability of eliminating 99.99% of the 38% of train accidents caused by human error isn’t clearly that probable anymore.

FRA can, and has, interpreted the law requiring PTC to eliminate train-to-train collisions as requiring that PTC restrict the speed of train-to-train collisions to no more than 20 mph.

Also, FRA has authorized unlimited movements, each of no more than 20 miles, of “yard transfer movements” hauled by non-PTC equipped locomotives in PTC territory.

FRA agreed to allow dispatching of a train into PTC territory when the locomotive’(s) on board computer(s) have failed the initialization process, during which the locomotive receives the limits to its movement authority, the temporary and permanent speed restrictions, the location of work zones, etc.

FRA took some of these actions in response to the Association of American Railroads’ petition, finding merit in AAR’s reasoning that requiring such transfer movements to comply with provision of RSIA 2008 would present the Class I’s with an unreasonable burden—namely, a burden that far outweighed the possible benefits of requiring full compliance.

Well, good for AAR—maybe. But you don’t get to have it any way you want it. You don’t get to create exceptions to and in PTC operation, and then argue that PTC makes train operations “fail-safe” to the point where a second crew member is redundant for safety. Actually, you do get to argue that. It’s a free country. You can argue anything you want. But don’t expect everyone to nod their heads and say “All right, OK,” and put his or her initials on the bottom line of that order.

I believe that the arguments about single-person train operation need to take into account the actual rail network in the U.S. and the actual operation of trains. Meaning what? Meaning that almost half the freight network is “dark territory”—without automatic signals, where train movements are governed by voice radio communication between trains and the trains’ controllers, the dispatchers. Meaning that movements are authorized by voice and must be copied and repeated, and repeated and approved, and that the crew members who have to abide by these movement authorities are required to know their content.

In both dark and signal territory, many switches to sidings, yards, and industrial tracks are hand-operated. Some switches can be operated from the cab of an approaching locomotive via radio transmission. Some can’t. In either case, operation of the switch means restoring it for “normal” movement immediately after the train using the switch clears. So who’s going to do that? Who’s going to report the train in the clear?

You say you are going to install technology, perhaps axle counters (in pairs, separated a short distance so direction can be determined) at the clearance point, and when this hardware registers that the train is in the clear, it will automatically restore the switch to the normal position? Great idea. But if you’re going to go to the expense of installing this technology, and the expense of the ongoing maintenance for such a system, why wouldn’t you just install CTC and be done with it, or actually be started with it?

And let’s consider, as we must, the exceptions, the unplanned, unintentional events that occur as part of our normal operations. For example, what about a train that has to set out a car other than the block of cars intended to be set out at a yard where a “general conductor” is stationed? This general conductor will directly execute the tasks of applying handbrakes to the cars that will remain on the main line; uncoupling the block of cars to be set out; instructing the locomotive engineer to pull ahead and to stop; lining the switch, advising the engineer to back up, how far to back up, and when to stop; uncoupling again; applying handbrakes to the cars set out on the yard track; instructing the engineer to pull ahead and when to stop; relining and locking the switch; instructing the engineer to back up, how far to back up, and to “stretch” the train after the hitch is made; establishing three-point protection so that the conductor can go between the cars and adjust the drawbars if necessary; to make the air hose connection; and to release the handbrakes?

How is all that going to be done when a train receives a message from a hot journal detector and it turns out there really is a hot journal and the car must be set out?

AAR, in its petitions to FRA, produced a study that showed the expected failure rate of PTC components and the impact that would have on network velocity (the average speed that trains operate anywhere on the system). FRA, unlike me, took that study seriously.

I believe the FRA study is a case of getting what you paid for: a study based on compounding potential failure rates in the abstract rather than based on actual failure rates in the concrete—like, say, the Panama Canal Railway’s experience, which is zero failures and zero false enforcements in the years its service has been “protected” by its PTC-equivalent system.

FRA took the study seriously enough to allow the dispatching of locomotives with a PTC initialization failure into PTC territory—something that today is not allowed for cab signal/speed control-equipped locomotives. So what happens when a single-person train has a PTC failure? Is the train dispatched? Does the locomotive engineer have to be ordered out of the terminal? Does the engineer then have to exercise a “good-faith” challenge, and then wait to hear from the superintendent?

Or ... does the train wait for a second person, who with PTC inoperative can perform the role of the second person in the cab of the BNSF train at Creston, Iowa, or the CSX train at Westville, Ind., or the UP train at Goodwell, Okla.?

You want to know my opinion? I’d tell the railroads to forget it, “it” being single-person train operation. I’d tell them that given the relatively backward technological platform governing our business, you’ve got nothing but heartache ahead if you push for single-person crews without upgrading—in details fine, small, and great—that platform. I’d tell them, when the technology is good enough to have zero crew members on a train, then you have a case for single-person crews—not before.

David Schanoes

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 1977, working for Conrail’s New Jersey Division. David joined Metro-North in 1985. He has spent his entire career in the operating division, 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 ten percent planning plus ninety percent 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.”

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