PTC: Ignore the circus. Here’s what’s really going on

Written by William C. Vantuono, Editor-in-Chief
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The railroad industry is making steady progress implementing Positive Train Control. You wouldn’t know it though, if you believed some of the choreographed histrionics the House Subcommittee on Railroads and its chairman displayed at a Feb. 15 hearing on PTC.

I’ll try to keep this first observation brief. Here’s Subcommittee Chair Jeff Denham (R-Calif.) in a press release that had me saying, “Really?”

Headline: “Denham stares down railroads: Americans are tired of excuses.”

Body Text: “Today, U.S. Rep. Jeff Denham, chairman of the Subcommittee on Railroads, Pipelines, and Hazardous Materials for the House Transportation and Infrastructure Committee, took to task representatives of the railroad industry, including Amtrak, on their failure to implement PTC safety technology that would have prevented crashes and saved lives: ‘If you have a timeline, we want to see that timeline. If you have questions or concerns or impediments, we want to know what those are. If you haven’t received funding, maybe you should request funding. But certainly, ignoring a congressional mandate again won’t be tolerated by either side of the aisle. I think the American public is tired of excuses. This is an amazing technology that will continue to improve the safety of our rails across the country.’”

You can stop laughing now.

None of the above has even the slightest shred of truth. Some of it is an outright, bald-faced lie. So what’s the purpose of Denham’s pontificating on PTC?

Contributing Editor Frank Wilner, who understands the Washington D.C. three-ring circus better than anyone I know, puts it in perspective: “Denham is playing to a political audience. That’s the way hearings go. It’s all choreographed. It’s political theater, and all the players understand. At the end of the day, Denham is an important pro-railroad vote.”

OK, I get it. But that doesn’t make his grandstanding any less disingenuous or distasteful.

For the record, there is no industry-wide “failure” to implement PTC. The industry is not “ignoring a congressional mandate.” As far as the American public being “tired of excuses,” 99.999% of the American public has no idea what PTC is or does!

(As far as Denham is concerned, come the November mid-term elections, he may have no voice at all, because he stands a good chance, according to some political analysts—Cook Political Report, for example—of being voted out of office. If that happens, I’ll be wearing an “amazing” smile.)

Enough with BS-filled, time-consuming, totally useless Congressional hearings. Here’s the real story on PTC, as presented recently at an Association of American Railroads briefing in Washington, supported by cold, hard facts—real numbers—by three key people overseeing the industry’s efforts:

  • Mike Rush, Senior Vice President, Safety and Operations, AAR.
  • Kathryn Kirmayer, Senior Vice President, Law and General Counsel, AAR.
  • Tom Schnautz, Assistant Vice President Mechanical, Norfolk Southern; Chairman, AAR PTC Interoperability Committee.

Left to right: AAR spokesperson Jessica Kahanek; Tom Schnautz, Assistant Vice President Mechanical, Norfolk Southern and Chairman, AAR PTC Interoperability Committee; Mike Rush, Senior Vice President, Safety and Operations, AAR; and Kathryn Kirmayer, Senior Vice President, Law and General Counsel, AAR. William C. Vantuono photo.

First, let’s dissect the Dec. 31, 2018 deadline. The statute says that, by this date, Class I freight railroads and Amtrak (on the lines it owns, not where it is a tenant operator) must have:

  • All PTC hardware installed.
  • All radio spectrum acquired.
  • More than 50% of PTC territory or route-miles implemented (out of about 60,000 miles that need to be equipped). Passenger railroads (except Amtrak) are required to have at least one territory fully operational by year-end.
  • All required employee training completed.

Provided these requirements are met, the Class I’s will qualify for an extension to Dec. 31, 2020, for which they must file at least 90 days out (the end of September 2018). 12-31-2020 is the absolute final statutory deadline. Testing must be completed, and PTC must be fully implemented by that date. Or else—well, we‘ll see.

For Class I’s, PTC territory refers to main lines that see at least 5 MGT (million gross tons) per year and that transport TIH (toxic inhalation hazard) and/or passenger traffic. The requirements for Class II and III railroads are somewhat different, in that only the passenger traffic rule applies.

The AAR says that “All the Class I’s are going to hit the four milestones to be granted an extension.” As of year-end 2017, industry-wide, 93% of wayside units and 97% of radio towers have been installed, 78% of locomotives have been equipped, and 87% of employees have been trained.

“In terms of where the Class I railroads are as an industry, 56% of the entire freight network that requires PTC implementation is already activated,” AAR spokeperson Jessica Kahanek explains. “Put another way, there is 44% of route-miles or territory left to be fully activated by 2020.”

As well, “Critical decisions coming up later this year will require a confirmed FRA Administrator.” Thankfully, that isn’t an issue any longer, as Ron Batory was finally sworn in as Federal Administrator on Feb. 13.

It’s important to keep in mind that a mere 4%—that’s right, 4%—of railroad main line accidents are “PTC preventable,” according to AAR data. These accidents, though, tend to be more serious, “dramatic,” resulting in injuries and death, and they’re caused by human error. Looking at the statistics, since 2000, the overall railroad accident rate has dropped 42%. The track-caused accident rate has dropped 51%. Derailments have declined 43%. The industry has been investing in technology and processes that address the three main causes of accidents: track failure (30%), equipment failure (15%) and human error (40%). The remaining 15% is attributable to miscellaneous causes.

PTC is designed to prevent train-to-train collisions, overspeed derailments, unauthorized incursions into maintenance work zones, and movement of a train through an improperly lined turnout. PTC will not prevent accidents caused by track or equipment failure, trespassing, grade crossing collisions caused by “improper motor vehicular movement,” and certain types of train operator error.

Equipment requirements? The industry is working on:

  • Outfitting more than 20,000 locomotives and 24,000 wayside locations, each with a unique address.
  • Geospatial mapping of thousands of track-miles with millions of network data points (roughly 2,000 data points per 100 track-miles).
  • PTC back office servers that aggregate and distribute train-specific data in real time.
  • PTC communications servers that provide connectivity among all elements.
  • An entirely new interoperable wireless communications network consisting of more than 400,000 components, and fitted with cryptographic protective measures.

All this, at a cost approaching $15 billion (not including annual maintenance costs), and yet PTC is still basically a safety overlay.

Let’s take a look at one railroad’s progress: Union Pacific.

UP said in a recent statement, “The company anticipates it will make all required deadlines for installing PTC on its network. As allowed by federal law, Union Pacific will continue to test and refine the immature technologies comprising the system in 2019-20. UP’s PTC footprint is the largest of all North American railroads, encompassing more than 17,000 route-miles, roughly 55% more than the next largest railroad.” (That would be BNSF, which is very far along.)

Union Pacific’s fourth-quarter 2017 accomplishments included:

  • Preparing 33 additional track segments for PTC operations, bringing the total number of track segments to 168 (92% complete).
  • Educating more than 2,700 additional employees on PTC operations, bringing the total number of employees trained to about 19,400 (75%).
  • Increasing by nearly 2,500 the number of route-miles in PTC operation, bringing the total number of route miles in PTC operations to 10,053 (59%).
  • 88% of required locomotives are equipped.
  • 100% of required radio towers are equipped.
  • 99.7%, or more than 17,000 miles, of required route-miles are equipped with PTC signal hardware.
  • Partially installed PTC hardware on 98% of its 5,515 locomotives earmarked for the technology.
  • Equipped and commissioned 4,220 locomotives with PTC hardware and software.

“Union Pacific plans to spend about $180 million on PTC in 2018 toward the current total estimated $2.9 billion cost.”

OK, Union Pacific, enough with the failures and excuses! Jeff is really ticked off, and you operate in his state! Shame on you!

Here’s where Amtrak stands with PTC, as provided by President and CEO Richard Anderson in his congressional testimony:

“The complexity of our operations requires Amtrak to use three different PTC systems across our network. Since 2000, Amtrak’s Northeast Corridor operations permitted to exceed 125 mph have depended on our first form of PTC called Advanced Civil Speed Enforcement System, or ACSES. By the end of 2015, to meet the original deadline of the 2008 Rail Safety Improvement Act, Amtrak had enabled ACSES for all our locomotives, cab cars and trainsets operating on the NEC. For equipment that operates on a 98-mile stretch of track Amtrak owns in Michigan and to permit higher speed operation on the newly purchased and upgraded line owned by the State, we have installed a second form of PTC equipment, called ITCS.

“To operate across the host railroads that make up 72% of the miles our trains travel, we are also installing a third form of PTC in our locomotives to integrate with the I-ETMS system in use by freight railroads. Having already PTC commissioned 338 units, we are on target to have 447 Amtrak-owned units fully commissioned and ready to operate before the Dec. 31, 2018, deadline.

“By law, each railroad owner is responsible for installation of PTC equipment on the tracks within their rights-of-way. Additionally, the hosts are responsible for reporting their PTC trackside readiness schedule to the FRA. Amtrak is working with the host railroads to develop an implementation schedule for PTC integration and testing. While 13 out of 20 host railroads that will be using I-ETMS have not provided a notice of intent to start PTC testing, the four Class I railroads that own the majority of the track over which Amtrak operates (BNSF, CSX, NS, and UP) have all provided letters of intent.

“Regarding the trackside installations for which Amtrak is responsible, Amtrak completed the ACSES PTC implementation on all but a few miles near terminals and stations on the NEC in December 2015 and on the Harrisburg Line during the first quarter of calendar year 2016. On our Michigan Line, trackside PTC implementation on our segment was fully completed in 2011,and the State-owned portion of our route to Detroit will be completed by June 2018. Installation of the ACSES PTC system on Amtrak’s Springfield Line will be completed by late Fall 2018 and we will soon begin hardware installation on the portions of the Hudson Line in New York we control, with implementation expected by Dec. 31, 2018.”

Anderson closed with a rather serious “warning,” if you want to call it that:

“It is now clear that we are likely to encounter four different scenarios where PTC is not yet operational by the end of the year. First, there will be carriers that have made sufficient progress to apply to FRA for an alternative PTC implementation schedule under the law. In these instances, Amtrak’s equipment will be ready for PTC operation, but additional work, testing or approvals are still required by the host railroad before the system is considered functional. We believe a significant number of routes outside of the NEC will face this situation. The question we must ask ourselves is whether we continue to operate over such routes until PTC is turned on and if so, what additional safety protections are appropriate to reduce risks?

“Second, there will be carriers over which we operate who appear unlikely to achieve sufficient progress to apply for an alternative PTC implementation schedule by year’s end. For any such route segments, Amtrak will suspend operations until such time as the carrier becomes compliant with the law.

“Third, there are areas over which we operate for which there is an FRA “Mainline Track Exclusion” in place exempting that segment from the PTC requirements based on the low levels of freight and passenger train traffic or the presence of low-speed operations, such as in yards and terminals. We are currently reviewing our policy on operating passenger trains on Exclusions to determine whether we have adequate safety mitigation practices in place for each territory. In certain areas, where signal systems are not in place, we will reconsider whether we operate at all.

“Finally, there may be railroads that operate over Amtrak tracks in the NEC that may not have sufficient PTC-commissioned rolling stock by the Dec. 31, 2018 deadline to operate normal services. Under the present rules, Amtrak cannot permit non-compliant equipment to be used over our railroad after the deadline and we will be working closely with our partners and the FRA to determine the best way to address this situation.”

Some context (and thank you again, Frank Wilner):

“The liability of operating ‘anyway’ could be catastrophic financially for Amtrak, which has a $295 million statutory cap on liability—still a lot of money to pay out given its annual subsidy is under $1 billion, and barely enough without accident payouts, as insurance doesn’t cover the entire award even with the cap. Moreover, premiums rise with each payout; and after “enough” payouts you face loss of your insurer. Additionally, Amtrak has a hold-harmless clause with all railroads over which it operates, meaning Amtrak pays for damage to its own equipment, while the host railroad is responsible for its trains, cargo and tracks.”

In conclusion: Excuses? Failure? Ignoring a congressional mandate? “Staring down the railroads?”

I can’t stop laughing.

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