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Showing posts with label regulation. Show all posts
Showing posts with label regulation. Show all posts

Saturday, September 7, 2024

Decision 2024 for the Signaling Single Issue Voter

Just like in 2020 I thought I'd provide some political analysis for the single issue railroad signaling single issue voter. Not sure who that would be exactly, but in a country this big it has to be somebody. In 2020 the big political signaling issue was PTC and the Trump administration's general failure to soften the regulations or roll it back before PTC driven signal replacement projects ruined the legacy infrastructure. In 2024 PTC is still proving to be a problem in terms of ETMS outages cancelling passenger services, but I don't see either party lifting a finger to solve the problem and almost all the vintage signaling is gone anyway.

In terms of regulation in general fears that the East Palestine derailment would trigger a moral panic on the order of the 2008 Chatsworth crash proved to be unfounded and I have to give the Biden administration real credit for taking a political risk and not rushing through knee jerk regulations that would damage the rail industry. We might see a minimum distance between hotbox detectors well below the old 20 mile AAR standard, but several railroads like the Southern and N&W have been on shorter intervals for decades.

Of course one area where I would call regulations too weak was the FRA's decision to allow CSX to remove the cab signal system on the RF&P. Coded track circuits are still more reliable and secure than over the air data links running off internet connected servers and attempts to use ETMS as safety critical cab signaling is going to cause a bad day. Another regulatory issue that is also in also in the blind spot of both parties is the FRA's use of shadow regulations to throttle the deployment of higher (80+ mph) speed passenger rail service. This might find a sympathetic ear on the current supreme court, but since it doesn't affect Class 1 freight RR's industry is uninterested in mounting a challenge and passenger operators known they are beholden to public funding.

A major factor in favor current Democratic politics the focus on anti-trust and industrial consolidation. Today the biggest threat to interesting signaling is industry consolidation, as seen with CSX's snapping up Guilford and CP buying KCS. I would expect proposed east-west RR mergers, like BNCSFX or UPNS, not passing regulatory muster under a Harris administration. In terms of trade policy, the vast majority of signaling equipment is still produced domestically so tariffs aren't necessary to fight off some invasion of cheap Chinese signaling hardware because that threat simply doesn't exist.

Finally, because legacy signaling has been so thoroughly decimated, the only way forward is new rail projects, which is one of Biden's signature issues. While a lot of the projects that have been built have employed locally prevailing signal rules and styles, there is always the chance of a Caltrain style speed signaling conversion or expansion of the Northeast cab signal network. 

Therefore if you are looking for my opinion I would endorse the Democratic ticket primarily for blocking additional rail mergers and funding the construction of new signaled passenger routes. They have earned my trust on avoiding bad regulation and are no worse than the alternative in cleaning up the FRA's existing over-regulation.

Wednesday, November 30, 2022

The LIRR's Puzzling ESA PTC Waiver

As the opening day of the Long Island Rail Road's decades long East Side Access mega project approached there appeared a new hiccup. Apparently the ESA tunnels were not built to support some of the LIRR's diesel rolling stock that routinely runs to New York Penn Station. Setting aside how the LIRR managed to make their brand new tunnel more restrictive that what it typically the gold standard in limited clearance, someone somewhere noticed that a mis-routing could do a can opened job on an oversize train and demanded that the LIRR perform some mitigation. 

Reverse switch to remove roof.

The typical way one would accomplish this would be to have a system of interlocked high car detectors. Tripping a detector would immediately cancel the route and the train would be stopped via both the Cab Signal ATC and ACSES PTC systems. What was so baffling about the LIRR's PTC waiver request was that they were trying to install a new "Tunnel Collision Avoidance" capability to ACSES that would allow for a positive stop at a non-absolute signal or signal indication point. The ACSES positive stop system functions via a transponder telling the on board system to enforce a positive stop in X feet if no cab signal code or radio release is received. This feature was expanded to also cover trains without functioning CSS getting a positive stop at an absolute signal not displaying Rule 280a "Clear to Next Interlocking". TCA would likely work in the same way with a transponder setting up a "positive stop unless" condition combined with a high car detector linked radio release or a cab signal code being present. In fact I think it is actually the latter because part of the aforementioned waiver notes that the ESA tunnels all use only the 250hz cab signal carrier frequency and overheight equipment (DE/.DM30's with C3 coaches) cannot detect the 250hz carrier at all. (See note below)

So my reaction to this is why the heck is the LIRR scrambling to modify ACSES when this was seemingly a solved problem. The fact a waiver is being applied for at all answers part of my question as this must have become an issue only after all of the HAROLD design and signaling work was specified and completed. My Spidey sense tells me that the LIRR's original solution was the use of the 250hz CSS carrier that would drop the cab signals of Amtrak, Metro-North and DE/DM stock to Restricting, at which point the engineer would stop the train short of the low tunnel. Regardless, the Powers That Be demanded a positive stop and instead of adding a new absolute signal at the tunnel mouths, the LIRR decided to do a software fix. I can see how trying to add an HCD system to HAROLD could result in a lot of costly testing given the number of potential routes involved. (After all, the cost of testing prevented NS from even changing the Conrail era HCD recording at CP-BANKS until the general re-signaling project in 2018!), but a couple of extra holdout signals seem pretty straightforward. Based on the general discourse of NYC project management, I suspect the cost of constructing even something "simple" in New York City made a signal-vendor supplied software fix the "better" option.

Before I wrap this up I want to complete the NYC-Region trifecta of poor public sector planning, high cost and political posturing by pointing out the letter that accompanies the FRA's granting of the rather short term PTC waiver. With everything the LIRR is doing to prevent mis-routes including route-indicating signals, rulebook rules, locked out routes, ATC enforced 15mph speeds and the 250hz fail safe cab signal code trick, I would have expected the FRA to issue a letter that states something on the order of "you have gone above and beyond to mitigate this problem".  Instead the letter goes on at length about how everything I mentioned is somehow deficient and they reluctantly approve of the waiver. Here's an example.

"The Board also shares Brotherhood of Railway Signalmen’s concerns about LIRR’s existing hazard detection system not protecting Amtrak trains operating in the Harold Interlocking from being misrouted to the GCM tunnel. FRA notes, however, that if an Amtrak train operating with oversized rolling stock is routed towards the GCM tunnel, a series of redundant protections exist to prevent that train from entering the tunnel. First, if a route into the tunnel is incorrectly lined so that an Amtrak train with oversized rolling stock is lined for movement into the tunnel, the train’s PTC system will enforce a positive stop at either signal 11W or 65W. To proceed past either of those stop signals, the train engineer would have to obtain dispatcher permission to by-pass the PTC enforcement and would be held to a PTC enforced 15 miles per hour (mph) speed limit. Second, as a train approaches the signals and diverging switch that controls the tunnel entry track, the train crew will see routing arrows on the mast of the relevant interlocking signals (up to three signals in advance), which will illuminate white when a route is lined from any of the tracks to the GCM tunnel (the arrows will not illuminate if the track is not lined for the tunnel entrance). This will provide Amtrak train crews the opportunity to stop their train, as required by Amtrak’s special instructions. Third, in the event an oversized train passes the 11W or 65W signals because of human error or a failure of the PTC system, and the train crew does not notice the illuminated arrows and take appropriate action if they are operating an oversized train, LIRR’s cab signaling and ATC systems will protect the Amtrak train, as it would any oversized LIRR train, through the 250 Hz cab signal code which will provide an audible alarm and enforce restricted speed."

  If you don't want to read all that I can summarize in a 14 second video clip.


What's even more telling is that its the railroad signaling union that is explicitly complaining about the lack of TCA capacity. Just remember, whenever a Union is applying political pressure there is likely overtime to be had. Now, the Railroad Safety Board is a political entity and they are going to do whatever they can to cover their asses to the max and/or avoid political problems with unions that might still provide a few Democratic votes, but the waiver also includes at least 6 safety theatre-esque action items that will add more time and cost to the entire ESA enterprise. Is a mis-route possible? Absolutely, they happen all the time.Even with all the protections could we actually get the can-opener effect? Well an Amtrak Keystone did go to Cynwyd 🤷. Still, the likelihood of all these Swiss cheese holes lining up is remote, especially as there are countless locations along busy passenger tracks where a bad route can take a train into a yard or an out of service track and they aren't causing major safety problems. If rail is every going to deliver nice things, we can't have this level of of CYA virtue signaling coming from the top.

PS: The entire docket of documents related to this waiver, including that super useful HAROLD interlocking diagram, can be found here.

*Note: The PRR legacy Cab Signal System as now deployed in North America makes use of code rates in pulses per minute and one or more AC carrier frequencies in cycles per second (hertz). These can be combined to increase the number of usable codes if so desired. Railroads on Amtrak's Northeast Corridor make use of a 100hz carrier for the basic CSS codes and a 250hz carrier for additional codes that were added ~1999. The LIRR uses an expanded set of pulse code rates and therefore does not need a secondary frequency. This means they could make the EMU stock (M3's, M7's and M9's) sensitive to both a 100hz and 250hz carrier with the same code rates. All other equipment including Amtrak, Metro-North and DE/DM stock will receive a Restricting cab signal in the abstinence of a 100hz code.



Monday, September 21, 2020

Decision 2020

 With all the election talk going on there was one take noticeably absent from the public discourse.  That would be who should one vote for if their number one concern is railway signaling.  Of course this is probably an uncommon point of view, but thanks to the law of large numbers and the internet generally supporting long tail interests, I might as well take a crack at it because I am in need of some filler content. 

 In 2016 the major issue affecting the historical quality and interestingness in the United States was the PTC requirement.  The $15 billion unfunded mandate was signed into law by a Republican president in 2008 with a 2015 deadline and then kicked down the road when the initial date proved unworkable. The law doesn't ban old signals or even require their replacement, but it does require new hardware and testing and at that point it was suddenly cheaper just to replace the whole kit and caboodle. In 2016 Donald Trump was presented as the pro-business, anti-regulation candidate and therefore presented a chance that the PTC requirement would be eliminated.

Four years later Trump has gone on crusades against efficient light bulbs and non-toxic detergent, but not only has the PTC mandate been left untouched, the Trump controlled FRA was at various points threatening popular commuter rail systems with shutdown if they did not waste more money on it.  The truth of the matter is that in 2020 the PTC issue is pretty much dead because there is almost nothing left to save.  Historic signaling has been burned like a California wildfire and with nothing left to lose there is only someone to blame and that would be the Trump Administration.

While the coal industry is completely collapsing even with Trump's support, from a signaling perspective a complete coal collapse would actually be beneficial as past a certain point there would be no business case to upgrade the last patches of N&W/C&O signaling in the coal regions of the east.  As we have seen in Florida and Michigan, CSX short line spin-offs have preserved large amount of classic Seaboard and Chessie signaling.  It's a shame coal didn't collapse a decade ago as it would have likely saved much of the historic West Virginia signaling scene.

The last major signaling related issue I want to discuss is the ability to document signaling from passing passenger trains, which requires A) passenger services and B) traditional rolling stock.  In terms of A, Amtrak has been brought to its knees with Trump connected CEO's axing both private cars and rare millage excursions.  The failure of the recent stimulus talks has now cut Amtrak LD services to tri-weekly.  In term of B, nothing has been done to toe the line in terms of American style crash resistance requirements and more and more European style rolling stock is showing up on the American rail network.  I will give Trump credit for working with congress to ban the Chinese rolling stock company, CRRC, but the regulatory environment is not helping the case for front or rear facing windows on passenger rolling stock. 

In 2020 the choice is clear.  "Amtrak" Joe Biden literally cannot make things any worse in terms of PTC or crappy rolling stock, but he will most certainly increase passenger rail funding which means more trains on more lines and more kinds of signals.  They might not be the most interesting *cough*Denver RTD*cough*, but at least it's something and uses traditional cab signaling.