A friend just today sent me a copy of an article by a Mr. Steve Chapman that appeared way back on 12 December in the Chcago Tribune, "The Wrong Lesson of the Metro-North Accident" hence my tardy reply to what is older than yesterday's headlines.
Nevertheless since I am a professional in the industry Mr. Chapman chose to write about, I thought he might appreciate some substantive criticism and correction to the claims in his article. Call me an optimist..
Mr. Chapman doesn't want anyone to think that the Metro-North accident should be taken as evidence for the installation of PTC as specified, and scheduled, in the RSIA of 2008. That's the lesson he wants all to learn-- or not learn. "Don't learn this!"is the theme of Mr. Chapman's column.
He doesn't mind, apparently, if we learn that there are and were solutions available to prevent the overspeed derailment on Metro-North that did not involve the installation of Positive Train Control. Metro-North already deploys continuously coded cab-signals, with signal mandated maximum speeds automatically enforced on its railroad. The application of a "medium code" south of CP 12 would have forced the engineer to begin and maintain deceleration to 30 mph at least 3500 feet prior to entering the restricted area. Metro-North has done exactly this since the derailment.
He doesn't mind if we learn that, while the collision at Chatsworth, California in 2008 was the incident that prompted the Congress to enact the Rail Safety Improvement Act of 2008, mandating the installation of PTC on Class 1 and passenger railroads over certain portions of the rail network, it was not the only accident that made the case for PTC so strong, and the delay in its installation so painful.
Chatsworth was the culminating accident. For about 12 years prior to Chatsworth, the NTSB has been recommending the installation of PTC, and pretty much to no avail. In those 12 years before, and the years since Chatsworth, there have been, according to my review of the NTSB database, 28 railroad accidents that have resulted in 107 fatalities. Now that's only the accidents that produced an employee or passenger fatality that could have been prevented by PTC system. This does not include monetary amounts of damages; this does not include the accidents in which passengers and employees were injured, not matter how severely, but did not result in a fatality.
He doesn't mind if we learn, in fact he tells us that the estimate for PTC implementation over 60,000 miles of railroad identified by FRA's interpretation of the law is a cool $10 billion.
He certainly doesn't mind if we learn that the business case suggests that the cost outweighs the benefits to the business of railroading.
I think as a professional in this industry that it's not quite so clear that the costs outweigh the benefits to the 107 people killed, the families and loved ones of the 107 killed, or the next 107 to be killed and their families. You know what I mean? Easy it might be to say, well that's less than 7 people a year, unless of course you happen to be one of the seven-- and I don't see anyone stepping up to volunteer, do you?
I also think we should learn that Positive Train Control is not simple, but we also need to learn that it is not "unproven" "experimental" technology. Amtrak on its NEC territory has installed a precursor to PTC called ACSES, which in conjunction with its existing cab signals and train control systems will provide, and is already providing, effective positive train control. In addition, GE's ITCS, Incremental Train Control System, has been installed on a portion of the line between Chicago and Detroit and is providing the enforcement and protective functions required by the law. Moreover, PTC has been in use on the Panama Canal Railways for several years and its application has been endorsed by the operating management of that railway.
The fact of the matter is is that "cost benefit" presumes that the only case that can be made for the application of any improvement is a business case. For 150 years, the law of this land has been that railroads are not just businesses, but are also public utilities, whose regulation for the common good, the collective welfare, the public safety is a right, and an obligation upon the government.
A former colleague in the railroad industry studied the history of the cab signal, automatic train stop, and automatic speed control systems that the former ICC, in the first decades of the 20th century, directed US railroads to develop and install in accordance with an earlier Congressional mandate. These systems were not, in comparison to PTC, all that complicated, or expensive. And what did he find? Many things. The technical and engineering staffs of the railroad developed systems that met or exceeded the requirements. These systems were improved as the rank and file operating personnel became more adept at defeating the systems. He also documented how railroads resisted the directives, appealed the requirement on the basis of cost, and technical complexity and interruption of service during installation.
When the Great Depression hit, the railroads appealed for, and were allowed to, initiate the dismantling of the systems that had already been installed on sections of the rail network.
I might be sympathetic to those who say that directing so vast a sum of money to PTC might starve the railroads of the cash necessary for other needed improvements, but that argument against PTC can be and is made against those improvements, or repairs. The "cost" outweighs the "benefit."
Does anyone think that in the last 5 years the railroads trying to convince Congress to push-back the date for PTC installation have not been exercising the very same "cost-benefit" disqualification to those areas like bridge repair, track upgrades, improved training, and even highway grade crossings which account for the overwhelming bulk of fatal accidents on railroads?
If Congress mandated that all crossings be equipped with protection that prevents a driver from going around the gate, the screams of "unfunded mandate" and "cost prohibitive, benefit minimal" wouldn't be heard from Maine to California?
Sure, it's quite clever to state, as Mr. Chapman does, "No one doubts the system would prevent injuries and fatalities. But if that were the sole consideration, we'd all be driving armored vehicles to the grocery and wearing bulletproof vests"-- except it misses the point-- we regulate road traffic; we insist on unfunded mandates like seat belts and air bags; we sometimes even try to keep guns out of the hands of those who use them against the public interest (although we don't try too hard).
If cost-benefit analysis had been around in 1872, we would never have equipped railroads with the closed track circuit, the single most important advance in both rail safety and operating efficiency.
Every operating decision is a financial decision on the railroad, and vice-versa. There's no doubt of that. Every railroad operating officer knows that. We make our decisions knowing we have to reconcile those elements, spending money, sometimes, on some things that don't add immediately, directly to the bottom line, simply for the reason that, as every railroad book of operating rules states, safety is of the first importance in the discharge of duty. PTC is just that type of "some thing."
And that's the beginning of the lesson, not the end.
December 24, 2013
Now I'm Back
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